COMMISSIONER OF INCOME TAX vs. PUNNIAMOORTHY PILLAI

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TCA/120/2023HC Madras19 August 2025Bench: Honourable The CHIEF JUSTICE4 pages
AI SummaryDismissed

What did the High Court hold?

The High Court, upon hearing the learned counsel for both the appellant/Revenue and the respondent/assessee, noted the submission by the Revenue that the case involved a low tax effect. Citing Circular No.05/2024 and Circular No.09/2024, the Revenue indicated its decision not to pursue the appeal further, though it sought to keep the question of law open. Consequently, the High Court dismissed the appeal. No order as to costs was made. The specific findings of the ITAT or the substantive legal questions that were to be decided by the High Court are not elaborated upon as the appeal was disposed of on the basis of the Revenue's submission and the low tax effect circulars.

What were the facts?

The Commissioner of Income Tax, Trichy (Appellant/Revenue) filed an appeal under Section 260A of the Income Tax Act, 1961, against an order of the Income Tax Appellate Tribunal (“C” Bench, Chennai) dated 22.6.2022 in ITA No.285/Mds/2022. The appeal was filed against Punniamoorthy Pillai Department Stores (Respondent/Assessee). The specific assessment year(s) and the amount in dispute are not recorded in the judgment. The procedural history leading to the Tribunal's order is not detailed.

What were the issues?

The appeal was filed by the Revenue. The primary issue was whether the appeal should be admitted and decided on merits. The Revenue, through its counsel, submitted that the case has a low tax effect. The Revenue relied on 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. Based on these circulars, the Revenue stated it did not wish to proceed with the matter, while requesting that the question of law be kept open for consideration in an appropriate future case. The Assessee's contentions are not recorded in the judgment.

Which sections of the Income-tax Act were involved?

Section 260A

AI-generated summary — verify with the full judgment below

T.C.A.No.120 of 2023 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 19.08.2025 CORAM : THE HONOURABLE MR. MANINDRA MOHAN SHRIVASTAVA, CHIEF JUSTICE AND THE HONOURABLE MR.JUSTICE SUNDER MOHAN T.C.A.No.120 of 2023 The Commissioner of Income Tax Trichy Appellant Vs Punniamoorthy Pillai Department Stores No.1476, South Rampart, Thanjavur-613 001 Respondent Prayer: Appeal filed under Section 260A of the Income Tax Act, 1961 against the order of the Income Tax Appellate Tribunal “C” Bench, Chennai, dated 22.6.2022 in ITA No.285/Mds/2022. For Appellant: Mr.V.Mahalingam Sr. Standing Counsel For Respondent: Mr.R.Venkatanarayanan for M/s.Subbaraya Aiyar Padmanabhan and Ramamani ____________ Page 1 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 21/08/2025 05:53:10 pm ) T.C.A.No.120 of 2023 JUDGMENT (Delivered by the Hon'ble Chief Justice) Heard learned counsel for the appellant/Revenue and learned counsel for the respondent/assessee. 2. At the outset, learned counsel for the Revenue fairly submits that it is a case having low tax effect. Therefore, in view of the 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, the appellant/Revenue does not wish to proceed with the matter, though the question of law may be kept open for consideration in the appropriate matter. 3. In that view of the matter, the appeal stands dismissed. There shall be no order as to costs. (MANINDRA MOHAN SHRIVASTAVA, CJ) (SUNDER MOHAN,J)

19.08.2025 Index : Yes/No Neutral Citation : Yes/No bbr ____________ Page 2 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 21/08/2025 05:53:10 pm ) T.C.A.No.120 of 2023 To: 1. The Assistant Registrar Income Tax Appellate Tribunal “C” Bench, Chennai. 2. The Principal Commissioner of Income Tax, Madurai-1. 3. The Income Tax Officer, Circle (OSD)-1, Trichy. ____________ Page 3 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 21/08/2025 05:53:10 pm ) T.C.A.No.120 of 2023 THE HON'BLE CHIEF JUSTICE AND SUNDER MOHAN,J. bbr

TCA No.120 of 2023

19.08.2025 ____________ Page 4 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 21/08/2025 05:53:10 pm )

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