PRINCIPAL COMMISSIONER OF INCOME TAX vs. M/s. The Investment Trust of India Ltd.,

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TCA/141/2022HC Madras26 August 2025Bench: Honourable The CHIEF JUSTICE4 pages
AI SummaryDismissed

What did the High Court hold?

The High Court held that the appeals should be dismissed. This decision was based on the submission made by the Revenue's counsel that the cases involved a low tax effect. In accordance with 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 did not wish to pursue the matter further. The Court accepted this submission and accordingly dismissed the appeals. The questions of law were expressly left open for consideration in an appropriate matter. No order as to costs was made. The operative direction was the dismissal of the appeals.

What were the facts?

These appeals were filed by the Principal Commissioner of Income Tax, Chennai, against M/s. The Investment Trust of India Ltd. The appeals challenged the common order dated 17.05.2021 passed by the Income Tax Appellate Tribunal ('C' Bench, Chennai) in ITA Nos.728/CHNY/2014 & 1809/CHNY/2014. The appeals were filed under Section 260A of the Income Tax Act, 1961. The Revenue, represented by learned counsel, submitted that the cases involved a low tax effect. Consequently, in view of Circular No.05/2024 dated 15.03.2024 and Circular No.09/2024 dated 17.09.2024, the Revenue did not wish to proceed with the matter, while reserving the right to have the questions of law considered in an appropriate future case.

What were the issues?

1. Whether the appeals filed by the Revenue should be dismissed in light of the low tax effect and the relevant CBDT circulars? (Question of law and procedure, turning on CBDT Circulars No.05/2024 and 09/2024). Assessee's Contention: The judgment does not record any specific contentions made by the assessee. The assessee was represented by counsel. Revenue's Contention: The Revenue, through its counsel, submitted that the cases had a low tax effect. Therefore, in view of Circular No.05/2024 dated 15.03.2024 and Circular No.09/2024 dated 17.09.2024, the Revenue did not wish to proceed with the matter. The Revenue also stated that the questions of law could be kept open for consideration in an appropriate matter.

Which sections of the Income-tax Act were involved?

Section 260A

AI-generated summary — verify with the full judgment below

TCA Nos.141 & 143 of 2022 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 26.08.2025 CORAM : THE HONOURABLE MR. MANINDRA MOHAN SHRIVASTAVA, CHIEF JUSTICE AND THE HONOURABLE MR.JUSTICE SUNDER MOHAN TCA Nos.141 & 143 of 2022 Principal Commissioner of Income Tax Company Circle III(2) Chennai 600 034. .. Appellant Vs. M/s. The Investment Trust of India Ltd. 1, Krishnamma Road Nungambakkam Chennai 600 034 PAN: AABCR6577K .. Respondent Prayer : Appeals filed under Section 260A of the Income Tax Act, 1961 against the common order dated 17.05.2021 passed in ITA Nos.728/CHNY/2014 & 1809/CHNY/2014 on the file of Income Tax Appellate Tribunal 'C' Bench, Chennai. ____________ Page 1 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 28/08/2025 05:40:09 pm ) TCA Nos.141 & 143 of 2022 For Appellant : Mr.T.Ravikumar Senior Standing Counsel For Respondent : Mr.R.Venkatanarayanan For M/s. Subbaraya Aiyar Padmanabhan 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/assessee. 2. At the outset, learned counsel for the Revenue fairly submits that these are cases of 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 questions of law may be kept open for consideration in the appropriate matter. ____________ Page 2 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 28/08/2025 05:40:09 pm ) TCA Nos.141 & 143 of 2022 3. In that view of the matter, the appeals stand dismissed. There shall be no order as to costs. (MANINDRA MOHAN SHRIVASTAVA, CJ) (SUNDER MOHAN,J)

26.08.2025 Index : Yes/No Neutral Citation : Yes/No kpl To 1. The Assistant Registrar Income Tax Appellate Tribunal “B” Bench, Chennai. 2. The Commissioner of Income Tax (Appeals) III Chennai. 3. The Assistant Commissioner of Income Tax, Company Circle III(2) Chennai. ____________ Page 3 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 28/08/2025 05:40:09 pm ) TCA Nos.141 & 143 of 2022 THE HON'BLE CHIEF JUSTICE AND SUNDER MOHAN,J. (kpl)

TCA Nos.141 & 143 of 2022

26.08.2025 ____________ Page 4 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 28/08/2025 05:40:09 pm )

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