Commissioner Of Income Tax vs. Watanmal Boolchand Company Ltd.,

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TCA/141/2025HC Madras01 August 2025Bench: Honourable The CHIEF JUSTICE4 pages
AI SummaryDismissed

What did the High Court hold?

The High Court held that the questions of law proposed by the appellant in the present appeal have already been answered by this Court in an earlier judgment. Specifically, the Court referred to its decision in the case of Commissioner of Income Tax v. Sutherland Global Services Inc., delivered on 10.6.2025 in T.C.A.Nos.80, 81 and 82 of 2025. Based on this submission by the Revenue's counsel, the High Court found no reason to re-examine the same issues. Therefore, the appeal was dismissed. The ratio decidendi is that if the issues raised in an appeal have been conclusively decided by the same court in a prior case, a subsequent appeal raising identical issues can be disposed of summarily based on the earlier decision, especially when conceded by the appellant.

What were the facts?

The appeal is filed by the Commissioner of Income Tax, International Taxation, Chennai (appellant) against the order of the Income Tax Appellate Tribunal (ITAT), "D" Bench, Chennai, dated 22.12.2023 in IT(TP)A.No.30/Chny/2022. The respondent is Watanmal Boolchand Company Ltd. The appeal is filed under Section 260A of the Income Tax Act, 1961. The High Court of Judicature at Madras is hearing the appeal. The procedural history leading to this appeal involves the ITAT passing an order which is now under challenge before the High Court.

What were the issues?

1. Whether the questions of law proposed by the appellant in this appeal stand answered by this Court earlier in the case of Commissioner of Income Tax v. Sutherland Global Services Inc. [Judgment dated 10.6.2025 in T.C.A.Nos.80, 81 and 82 of 2025]? (Question of law) Assessee's Contentions: Not recorded in the judgment. Revenue's Contentions: The learned counsel for the appellant (Revenue) fairly submits that the questions of law proposed by the appellant in this appeal stand answered by this Court earlier in the case of Commissioner of Income Tax v. Sutherland Global Services Inc. [Judgment dated 10.6.2025 in T.C.A.Nos.80, 81 and 82 of 2025].

Which sections of the Income-tax Act were involved?

Section 260A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “D”

T.C.A.No.141 of 2025 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 01.08.2025 CORAM : THE HONOURABLE MR. MANINDRA MOHAN SHRIVASTAVA, CHIEF JUSTICE AND THE HONOURABLE MR.JUSTICE SUNDER MOHAN T.C.A.No.141 of 2025 and C.M.P.No.18423 of 2025 The Commissioner of Income Tax International Taxation Chennai - 600 034. Appellant Vs Watanmal Boolchand Company Ltd, C/o. CRBS and Associates LLP, Chartered Accountants, No.37, 2nd Street, Alagiri Nagar, Vadapalani, Chennai - 600 026. Respondent Prayer: Appeal filed under Section 260A of the Income Tax Act, 1961 against the order of the Income Tax Appellate Tribunal “D” Bench, Chennai, dated 22.12.2023 in IT(TP)A.No.30/Chny/2022. ____________ Page 1 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 04/08/2025 07:50:52 pm ) T.C.A.No.141 of 2025 For Appellant: Ms.R.Hemalatha for Mr.Karthik Ranganathan For Respondent: Mr.T.Banusekar

ORDER (Delivered by the Hon'ble Chief Justice) Ms.R.Hemalatha, learned counsel for the appellant; and Mr.T.Banusekar, learned counsel for the respondent, fairly submit that the questions of law proposed by the appellant in this appeal stand answered by this Court earlier in the case of Commissioner of Income Tax v. Sutherland Global Services Inc. [Judgment dated 10.6.2025 in T.C.A.Nos.80, 81 and 82 of 2025]. In view of the above statement, this appeal is also dismissed. There shall be no order as to costs. Consequently, interim application stands closed. (MANINDRA MOHAN SHRIVASTAVA, CJ) (SUNDER MOHAN,J)

01.08.2025 Index : Yes/No Neutral Citation : Yes/No sasi ____________ Page 2 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 04/08/2025 07:50:52 pm ) T.C.A.No.141 of 2025 To: 1. The Assistant Registrar Income Tax Appellate Tribunal Chennai Benches, Chennai. 2. The Deputy Commissioner of Income Tax International Taxation Circe 2(2) Chennai. ____________ Page 3 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 04/08/2025 07:50:52 pm ) T.C.A.No.141 of 2025 THE HON'BLE CHIEF JUSTICE AND SUNDER MOHAN,J. (sasi)

TCA No.141 of 2025

01.08.2025 ____________ Page 4 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 04/08/2025 07:50:52 pm )

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