THE COMMISSIONER OF INCOME TAX TDS-1 CHANDIGARH vs. M/S PUNJAB STATE CO-OP SUPPLY AND MARKETING FEDERATION LTD

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ITA/143/2021HC Punjab & HaryanaPHHC01033485202126 September 2025Bench: MRS. JUSTICE LISA GILL,MRS. JUSTICE MEENAKSHI I. MEHTA1 pages
AI SummaryWithdrawn

What did the High Court hold?

The High Court held that the appeal is to be dismissed as withdrawn. The reasoning provided is that the appellant, the Commissioner of Income Tax (TDS)-1, Chandigarh, has received specific instructions to withdraw the appeal. This instruction is based on Circular No. 9 of 2024 dated 17.09.2024, issued by the Ministry of Finance, Department of Revenue, CBDT, Government of India, due to the tax effect involved being under Rs. 2 Crores. The Tribunal's order dated 19.11.2020, which is the subject of the appeal, was not decided on its merits. The operative direction is the dismissal of the appeal as withdrawn. No issues were expressly left undecided as the appeal was disposed of on a procedural ground.

What were the facts?

The appeal was filed by the Commissioner of Income Tax (TDS)-1, Chandigarh, under Section 260A of the Income Tax Act, 1961, against an order dated 19.11.2020 passed by the Income Tax Appellate Tribunal, Chandigarh Bench ‘B’, Chandigarh, in ITA No.1452/Chd/2019. The respondent in the appeal is M/s Punjab State Co-op Supply and Marketing Federation Ltd. The appeal was listed before the High Court of Punjab & Haryana at Chandigarh. The specific assessment year(s) are not mentioned in the provided text. The amount in dispute is stated to be under Rs. 2 Crores.

What were the issues?

1. Whether the appeal filed by the Revenue is to be withdrawn in view of the CBDT Circular No. 9 of 2024 dated 17.09.2024, given that the tax effect involved is under Rs. 2 Crores? The Revenue, through its learned Senior Standing Counsel, submitted that it has specific instructions to withdraw the appeal. This instruction is based on Circular No. 9 of 2024 issued by the Ministry of Finance, Department of Revenue, CBDT, Government of India, which mandates withdrawal of appeals where the tax effect is below a certain threshold (in this case, under Rs. 2 Crores). The judgment does not record any specific arguments from the assessee's side regarding this procedural submission.

Which sections of the Income-tax Act were involved?

Section 260A

AI-generated summary — verify with the full judgment below

215

IN THE HIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH

ITA No.143 of 2021

Date of Decision: 26.09.2025

The Commissioner of Income Tax (TDS)-1, Chandigarh

…Appellant

Versus

M/s Punjab State Co-op Supply and Marketing Federation Ltd.

…Respondent

CORAM: HON’BLE MRS. JUSTICE LISA GILL HON’BLE MRS. JUSTICE MEENAKSHI I. MEHTA

Present:- Mr. Ranvijay Singh, Senior Standing Counsel,

for appellant-Income Tax Department.

***** LISA GILL, J.(Oral) 1.

Present appeal has been filed under Section 260A of the Income Tax Act, 1961, against order dated 19.11.2020 passed by learned Income Tax Appellate Tribunal, Chandigarh Bench ‘B’, Chandigarh, in ITA No.1452/Chd/ 2019. 2.

Learned counsel for appellant submits that as the tax effect involved in this appeal is under Rs.2 Crores, he has specific instructions to withdraw this appeal in view of circular No.9 of 2024 dated 17.09.2024 issued by Ministry of Finance, Department of Revenue, CBDT, Government of India. 3.

Appeal is, accordingly, dismissed as withdrawn. 4.

Pending application(s), if any, stand(s) disposed of.

(LISA GILL)

JUDGE

26.09.2025

(MEENAKSHI I. MEHTA) neetu

JUDGE Whether speaking/reasoned: Yes/No

Whether Reportable: Yes/No NEETU RANI 2025.09.29 12:50 I attest to the accuracy and authenticity of this order/judgment PHHC, CHD

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