PRINCIPAL COMMISSIONER OF INCOME TAX vs. Kumaran Systems Pvt.Ltd

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TCA/102/2022HC Madras03 July 2025Bench: Honourable The CHIEF JUSTICE4 pages
AI SummaryWithdrawn

What did the High Court hold?

The High Court held that the appeal stands dismissed as withdrawn. The reasoning provided is that the counsel for the appellant (Revenue) stated that the monetary limit involved in the appeal is below the limits prescribed in Circular No.05/2024 and Circular No.09/2024, and she had instructions to withdraw the appeal on this basis. The withdrawal was explicitly stated to be without conceding the stand of the Department. The operative direction is that the appeal is dismissed as withdrawn, with no order as to costs. No specific issue was decided on merits, and no part of the Tribunal's order was upheld or set aside.

What were the facts?

The appeal was filed by the Principal Commissioner of Income Tax, Central Circle 4(2), Chennai, against M/s. Kumaran Systems Pvt Ltd. The appeal challenges an order dated 09.08.2021 passed by the Income Tax Appellate Tribunal, Madras 'D' Bench, Chennai. The assessment year(s) and the specific amount in dispute are not recorded in the judgment. The procedural history indicates that the appeal was filed under Section 260A of the Income Tax Act, 1961. The respondent, M/s. Kumaran Systems Pvt Ltd., did not appear before the High Court.

What were the issues?

1. Whether the appeal, filed by the Revenue, should be withdrawn due to the monetary limit prescribed by CBDT Circulars No.05/2024 and 09/2024. This is a question of procedural compliance and administrative policy. Assessee's contentions: No appearance recorded for the assessee. Revenue's contentions: The counsel for the appellant (Revenue) stated that the monetary limit involved in the appeal is below the prescribed limits in Circular No.05/2024 and Circular No.09/2024, issued by the Ministry of Finance, Department of Revenue, Central Board of Direct Taxes. The counsel further stated that she has instructions to withdraw the appeal on this ground, without conceding the stand of the Department.

Which sections of the Income-tax Act were involved?

Section 260A

AI-generated summary — verify with the full judgment below

T.C.A.No.102 of 2022

IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 03.07.2025 CORAM : THE HON'BLE MR.K.R.SHRIRAM, CHIEF JUSTICE AND THE HON'BLE MR.JUSTICE SUNDER MOHAN T.C.A.No.102 of 2022 Principal Commissioner of Income Tax Central Circle 4(2) Chennai 600 034. .. Appellant Vs. M/s. Kumaran Systems Pvt Ltd. Plot No.28/A-41, III Main Road 6th Cross, SIPCOT IT Park Siruseri, Kanchipuram 603 103. PAN: AABCK3992P .. Respondent Prayer : Appeal filed under Section 260A of the Income Tax Act, 1961 against the order dated 09.08.2021 passed in IT(P)A No.95/CHNY/2018 on the file of the Income Tax Appellate Tribunal, Madras 'D' Bench, Chennai. For Appellant : Ms.V.Pushpa For Respondent : No appearance __________ Page 1 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 08/07/2025 08:34:49 pm ) T.C.A.No.102 of 2022

JUDGMENT (Judgment of the Court was delivered by the Hon'ble Chief Justice) Ms.Pushpa states that the monetary limit involved in this appeal is below the monetary limit prescribed in Circular No.05/2024 dated 15.03.2024 and Circular No.09/2024, dated 17.09.2024, issued by the Ministry of Finance, Department of Revenue, Central Board of Direct Taxes, Government of India. Counsel says that she has instructions, therefore, to withdraw the appeal. 2. Counsel also states that the withdrawal is only due to the monetary limit and without conceding the stand of the Department. 3. Appeal stands dismissed as withdrawn. There shall be no order as to costs. (K.R.SHRIRAM, CJ) (SUNDER MOHAN,J.)

03.07.2025 Index : Yes/No Neutral Citation : Yes/No kpl __________ Page 2 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 08/07/2025 08:34:49 pm ) T.C.A.No.102 of 2022

To 1. The Assistant Registrar Income Tax Appellate Tribunal Chennai Benches, Chennai. 2. The Deputy Commissioner of Income Tax Corporate Circle -4(2) Chennai.

__________ Page 3 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 08/07/2025 08:34:49 pm ) T.C.A.No.102 of 2022

THE HON'BLE CHIEF JUSTICE AND SUNDER MOHAN

,J.

(kpl)

T.C.A.No.102 of 2022

03.07.2025 __________ Page 4 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 08/07/2025 08:34:49 pm )

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