PRINCIPAL COMMISSIONER OF INCOME TAX-10 DELHI v. PINNACLE CLOTHING COMPANY

1. FACTS OF THE CASE

Revenue appealed against Pinnacle Clothing Company in ITA 117/2026. The order records that the tax effect falls below the limits in CBDT Circular 5/2024 dated 15 March 2024 read with Circular 9/2024 dated 17 September 2024.

Source: PDF pp.1–2

2. DISCUSSION BY THE COURT

Before considering tax effect, the Court condoned 708 days in refiling. Revenue then reported that the appeal fell below the limits in the two specified CBDT circulars.

Source: PDF pp.1–2

3. JUDICIAL DECISION

The appeal was dismissed on the stated low-tax-effect ground. No underlying tax merits were adjudicated.

Source: PDF pp.1–2

4. OUTCOME

Revenue’s appeal ended; all pending applications were disposed of.

Source: PDF pp.1–2

5. Expert Comments

AKHB editorial analysis, distinct from the Court’s findings.

Identify the actual disposal

The Court expressly condones 708 days in refiling under CM 9211/2026. The filing-delay application CM 9210/2026 is disposed of with the appeal; the order does not separately say that filing delay was condoned.

Source: PDF pp.1–2

Separate appellate closure from tax merits

The result favours Pinnacle Clothing Company only in ending this Revenue challenge. The Court supplies no independent reasoning approving a deduction, deleting an addition or invalidating reassessment. For any substantive reliance, the underlying appellate decision and its facts would need to be examined separately.

Source: PDF pp.1–2

Apply the recorded policy with its evidential limits

The order identifies both circulars but does not reproduce their full conditions or decide any exception. It therefore supports the recorded disposal, not a universal monetary-limit rule for other appeals. The assessment year and substantive statutory provisions remain unstated; assigning them from a filename or a neighbouring case would create unsupported facts.

Source: PDF pp.1–2