Pr. Commissioner of Income Tax, Delhi v. Janak Raj Gupta; Pr. Commissioner of Income Tax-4, Delhi v. GD Infrabuild Pvt. Ltd. (common order)

1. FACTS OF THE CASE

Revenue appealed against Janak Raj Gupta and GD Infrabuild Pvt. Ltd. in ITA 371/2026 and 372/2026. 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

The Court acted on the recorded low-tax-effect submission. The order does not set out the underlying tax controversy, assessment year or a calculation of the monetary limit.

Source: PDF pp.1–2

3. JUDICIAL DECISION

Both appeals were dismissed on the stated low-tax-effect ground. No underlying tax merits were adjudicated.

Source: PDF pp.1–2

4. OUTCOME

Both Revenue appeals ended under the common order. Pending applications were also dismissed.

Source: PDF pp.1–2

5. Expert Comments

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

Identify the actual disposal

ITA 371/2026 concerns Janak Raj Gupta; ITA 372/2026 concerns GD Infrabuild. The common disposal retains two respondents and two appeals, rather than treating their names as interchangeable.

Source: PDF pp.1–2

Separate appellate closure from tax merits

The result favours Janak Raj Gupta and GD Infrabuild Pvt. Ltd. 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