The Principal Commissioner of Income Tax 4 vs. M/s. Ashok Leyland Ltd.,

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TCA/154/2024HC Madras03 July 2025Bench: Honourable The CHIEF JUSTICE4 pages
AI SummaryWithdrawn

What did the High Court hold?

The High Court noted that the counsel for the Revenue stated that the monetary limit involved in the appeal was below the prescribed limits in Circular No.05/2024 and Circular No.09/2024. Based on instructions received, the counsel sought to withdraw the appeal. The Court was informed that the withdrawal was solely due to the monetary limit and not an admission of the Department's stand on merits. Consequently, the appeal was dismissed as withdrawn. No specific finding was made on the substantive issues of the case, as the appeal was disposed of on a procedural ground. The Court also stated that there would be no order as to costs.

What were the facts?

The appeal was filed by the Principal Commissioner of Income Tax-4, Chennai (the Revenue) against an order dated 08.09.2022 passed by the Income Tax Appellate Tribunal (ITAT), Chennai Bench, in Cross Objection No.02/CHNY/2019, arising from ITA No.2972/CHNY/2018. The respondent assessee is M/s. Ashok Leyland Limited, successor to M/s. Ashok Leyland Project Services Ltd. The appeal was filed under Section 260A of the Income Tax Act, 1961. The procedural history involves an order from the ITAT which is now under challenge before the High Court.

What were the issues?

1. Whether the appeal is maintainable in light of the monetary limits prescribed by CBDT Circulars? (Question of law) The Revenue, through its counsel, submitted that the monetary limit involved in this appeal is below the prescribed limits in 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 counsel stated that she had instructions to withdraw the appeal on this ground. The Revenue's contention was solely based on the monetary limit prescribed by the circulars, leading to the withdrawal 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.154 of 2024

IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 03.07.2025 CORAM : THE HON'BLE MR.K.R.SHRIRAM, CHIEF JUSTICE AND THE HON'BLE MR.JUSTICE SUNDER MOHAN T.C.A.No.154 of 2024 The Principal Commissioner of Income Tax-4 Chennai 600 034. .. Appellant Vs. M/s. Ashok Leyland Limited [Successor of M/s. Ashok Leyland Project Services Ltd.] No.1, Sardar Patel Road Guindy, Chennai 600 032. PAN: AAACA4651L .. Respondent Prayer : Appeal filed under Section 260A of the Income Tax Act, 1961 against the order dated 08.09.2022 passed in Cross Objection No.02/CHNY/2019 in ITA No.2972/CHNY/2018 on the file of the Income Tax Appellate Tribunal 'C' Bench, Chennai. For Appellant : Mrs.V.Pushpa Senior Standing Counsel For Respondent : Mr.R.Venkat Narayanan For M/s. Subbaraya Aiyar, Padmanabhan & Ramamani __________ Page 1 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 10/07/2025 11:33:07 am ) T.C.A.No.154 of 2024

JUDGMENT (Judgment of the Court was delivered by the Hon'ble Chief Justice) Ms.Pushpa states that the monetary limit involved in this appeal is below the monetary limit prescribed in 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. Counsel says that she has instructions, therefore, to withdraw the appeal. 2. Counsel also states that the withdrawal is only due to the monetary limit and without conceding the stand of the Department. 3. Appeal stands dismissed as withdrawn. There shall be no order as to costs. (K.R.SHRIRAM, CJ) (SUNDER MOHAN,J.)

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Index : Yes/No Neutral Citation : Yes/No kpl To 1. The Assistant Registrar Income Tax Appellate Tribunal Chennai Benches, Chennai. 2. The Commissioner of Income Tax (Appeals) Chennai.

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THE HON'BLE CHIEF JUSTICE AND SUNDER MOHAN

,J.

(kpl)

T.C.A.No.154 of 2024

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