THE COMMISSIONER OF INCOME TAX vs. M/S.C.R.NARAYANA RAO LLP

TCA/135/2021HC Madras16 December 2025Bench: Honourable The CHIEF JUSTICE3 pages

AI SummaryDismissed

What did the High Court hold?

The High Court of Judicature at Madras, in view of the submission made by the learned counsel for the Revenue, decided to dismiss the appeal. The Revenue, acknowledging the low tax effect of the case and citing recent circulars from the CBDT (Circular No. 05/2024 and Circular No. 09/2024), expressed its intention not to pursue the appeal further. The Court accepted this submission and consequently dismissed the appeal. The Court also noted that the question of law, though not decided on merits, would be kept open for consideration in an appropriate matter. No order as to costs was made.

What were the facts?

The appeal was filed by the Commissioner of Income Tax, Chennai (Revenue) against an order of the Income Tax Appellate Tribunal, Madras A Bench, Chennai, dated 27.09.2019, passed in ITA No.2968/Chny/2017. The respondent is M/s. C.R. Narayana Rao LLP, now amalgamated with M/s. CR Narayana Rao Consultants Pvt Ltd. The appeal was filed under Section 260A of the Income Tax Act, 1961. The judgment was delivered by the High Court of Judicature at Madras on 16.12.2025.

What were the issues?

The judgment does not explicitly frame specific questions of law. However, the core issue revolves around the Revenue's decision to withdraw from pursuing the appeal. The Revenue, through its Senior Standing Counsel, Mr. T.R. Ravi Kumar, submitted that the case has a low tax effect. Relying 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, 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 Respondent's counsel, Mr. R. Kumar, was present but no specific arguments were recorded for the respondent in relation to the merits of the appeal.

Which sections of the Income-tax Act were involved?

Section 260A

AI-generated summary — verify with the full judgment below

T.C.A.No.135 of 2021 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 16.12.2025 CORAM : THE HONOURABLE MR. MANINDRA MOHAN SHRIVASTAVA, CHIEF JUSTICE AND THE HONOURABLE MR.JUSTICE G.ARUL MURUGAN T.C.A.No.135 of 2021 The Commissioner of Income Tax Chennai. Appellant(s) Vs M/s.C.R.Narayana Rao Llp (now Amalgamated With M/s.CR Narayana Rao Consultants Pvt Ltd) No.10, Karpagambal Nagar Mylapore, Chennai 600004. Respondent(s) Prayer : Appeal filed under Section 260A of the Income Tax Act, 1961, against the order of the Income Tax Appellate Tribunal Madras A Bench, Chennai dated 27.09.2019 passed in ITA No.2968/Chny/2017. For Appellant(s): Mr.T.Ravi Kumar Senior Standing Counsel For Respondent(s): Mr.R.Kumar

__________ Page 1 of 3 https://www.mhc.tn.gov.in/judis ( Uploaded on: 18/12/2025 09:25:59 pm ) T.C.A.No.135 of 2021 JUDGMENT (Judgment of the Court was delivered by the Hon'ble Chief Justice) Heard learned counsel for the appellant/Revenue and learned counsel for the respondent. 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) (G.ARUL MURUGAN,J)

16.12.2025 kpl __________ Page 2 of 3 https://www.mhc.tn.gov.in/judis ( Uploaded on: 18/12/2025 09:25:59 pm ) T.C.A.No.135 of 2021 THE HON'BLE CHIEF JUSTICE AND G.ARUL MURUGAN,J. (kpl) T.C.A.No.135 of 2021

16.12.2025 __________ Page 3 of 3 https://www.mhc.tn.gov.in/judis ( Uploaded on: 18/12/2025 09:25:59 pm )

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