Commissioner Of Income Tax vs. Watanmal Boolchand Company Ltd,

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TCA/138/2025HC Madras31 July 2025Bench: Honourable The CHIEF JUSTICE4 pages
AI SummaryDismissed

What did the High Court hold?

The High Court held that the appeal did not present any substantial question of law for decision. This conclusion was reached because the Revenue's counsel conceded that the issues and questions of law raised in the present appeal had already been decided against the Revenue and in favour of the assessee in the case of Commissioner of Income-tax, International Taxation vs. Sutherland Global Services Inc., [(2025) 175 taxmann.com 897 (Madras)], decided on 10.06.2025. Consequently, the appeal was dismissed at the admission stage itself. No order as to costs was made. The interim application was also disposed of.

What were the facts?

The Revenue (Commissioner of Income Tax, International Taxation, Chennai) has filed an appeal under Section 260A of the Income Tax Act, 1961, against an order dated 22.12.2023 passed by the Income Tax Appellate Tribunal (ITAT), 'D' Bench, Chennai. The appeal pertains to Assessment Year 2007-08 and challenges the ITAT's decision in favour of the assessee, M/s. Watanmal Boolchand Company Ltd. The High Court is considering the admission of this appeal.

What were the issues?

1. Whether the appeal raises a substantial question of law, as required for admission under Section 260A of the Income Tax Act, 1961. Assessee's Contentions: The judgment does not record any specific contentions made by the assessee. The assessee is represented by their counsel. Revenue's Contentions: The learned counsel for the Appellant/Revenue raised an issue concerning the framing of a substantial question of law. However, the Revenue fairly admitted that the issue raised in this case and the questions of law proposed by them have already been answered against the Revenue and in favour of the assessee in a previous judgment by the High Court.

Which sections of the Income-tax Act were involved?

Section 260A

AI-generated summary — verify with the full judgment below

TCA No.138 of 2025 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 31.07.2025 CORAM THE HON'BLE MR.MANINDRA MOHAN SHRIVASTAVA, CHIEF JUSTICE AND THE HON'BLE MR.JUSTICE SUNDER MOHAN TCA No.138 of 2025 and CMP No.18344 of 2025 Commissioner of Income Tax International Taxation, Chennai 600 034. .. Appellant -vs- M/s.Watanmal Boolchand Company Ltd., Co/CRBS & Associates LLP, Chartered Accountants, No.37, 2nd Street, Alagiri Nagar, Vadapalani, Chennai 600 026. PAN : AABCW3559Q .. Respondent Prayer: Appeal filed under Section 260A of the Income Tax Act, 1961, against the order dated 22.12.2023 made in IT(TP)A No.29/CHNY/2022 on the file of the Income Tax Appellate Tribunal, “D” Bench, Chennai for the Assessment Year 2007-08. For Appellant : Mr.R.Karthik For Respondent : Mr.T.Banusekar * * * * * Page 1 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 05/08/2025 01:18:49 pm ) TCA No.138 of 2025 JUDGMENT (Delivered by the Hon'ble Chief Justice) Though the learned counsel for the Appellant/Revenue raised an issue considering framing of substantial question of law, he fairly admits that the issue raised in this case and the questions of law as proposed by him have already been answered against the Revenue and in favour of Assessee vide judgment dated 10.06.2025 in the case of Commissioner of Income-tax, International Taxation vs. Sutherland Global Services Inc., [(2025) 175 taxmann.com 897 (Madras)]. In that view of the matter, the appeal does not have any substantial question of law to be decided and therefore, dismissed at the admission stage itself. There shall be no order as to costs. Consequently, the interim application stands closed. (MANINDRA MOHAN SHRIVASTAVA, CJ.) (SUNDER MOHAN, J.) 31.07.2025 Index : Yes/No Neutral Citation : Yes/No sra Page 2 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 05/08/2025 01:18:49 pm ) TCA No.138 of 2025 To 1. The Income Tax Appellate Tribunal, 'D' Bench, Chennai. 2. The Commissioner of Income Tax International Taxation, Chennai 600 034. Page 3 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 05/08/2025 01:18:49 pm ) TCA No.138 of 2025 THE HON'BLE CHIEF JUSTICE AND SUNDER MOHAN

, J.

(sra) TCA No.138 of 2025 31.07.2025 Page 4 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 05/08/2025 01:18:49 pm )

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