PR. COMMISSIONER OF INCOME TAX -3 v. HERO MOTOCORP LTD. (SUCCESSOR OF M/S HERO INVESTMENTS PVT. LTD.)

1. FACTS OF THE CASE

Revenue appealed against Hero Motocorp Ltd. (successor of Hero Investments Pvt. Ltd.) in ITA 419/2026. 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.

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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.

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3. JUDICIAL DECISION

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

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4. OUTCOME

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

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5. Expert Comments

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

Identify the actual disposal

The successor description identifies the respondent in this appeal. The Court does not determine any legal consequence of the succession or decide whether an assessment in a predecessor’s name was valid.

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Separate appellate closure from tax merits

The result favours Hero Motocorp Ltd. (successor of Hero Investments 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.

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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.

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