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

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TCA/173/2025HC Madras10 September 2025Bench: Honourable The CHIEF JUSTICE4 pages
AI SummaryDismissed

What did the High Court hold?

The High Court observed that the learned counsel for the appellant (Revenue) fairly submitted that the issue and the questions of law proposed in the present appeal have already been answered against the Revenue and in favour of the assessee by a prior judgment of the High Court dated 10.06.2025 in the case of Commissioner of Income Tax, International Taxation v. Sutherland Global Services Inc. [(2025) 175 taxmann.com 897 (Madras)]. Based on this concession by the Revenue, the High Court found that the appeal did not present any substantial question of law for consideration. Consequently, the appeal was dismissed at the admission stage. The operative direction was to dismiss the appeal. No issue was expressly left undecided.

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 is against the ITAT's decision concerning M/s. Watanmal Boolchand Company Ltd. The specific assessment year(s) are not mentioned in the provided text. The appeal challenges the findings of the ITAT, which are not detailed here. The procedural history involves the Revenue filing this appeal before the High Court after the ITAT's order.

What were the issues?

1. Whether the appeal raises any substantial question of law for consideration by the High Court, as required under Section 260A of the Income Tax Act, 1961. The Revenue, through its learned counsel, submitted that the issue raised in this case and the proposed questions of law have already been decided against the Revenue and in favour of the assessee by a previous judgment of the High Court dated 10.06.2025 in the case of Commissioner of Income Tax, International Taxation v. Sutherland Global Services Inc. [(2025) 175 taxmann.com 897 (Madras)]. The Revenue did not present any arguments contrary to this submission. The Assessee's contentions are not recorded in the judgment.

Which sections of the Income-tax Act were involved?

Section 260A

AI-generated summary — verify with the full judgment below

TCA No.173 of 2025 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 10.09.2025 CORAM : THE HONOURABLE MR. MANINDRA MOHAN SHRIVASTAVA, CHIEF JUSTICE AND THE HONOURABLE MR.JUSTICE G.ARUL MURUGAN TCA No.173 of 2025 & CMP No.21820 of 2025 Commissioner of Income Tax International Taxation Chennai 600 034. .. Appellant Vs. M/s. Watanmal Boolchand Company Ltd. C/o. CRBS & Associates LLP, Chartered Accountants No.37, 2nd Street Alagiri Nagar Vadapalani Chennai 600 026. PAN: AABCW3559Q .. Respondent Prayer : Appeal under Section 260A of the Income Tax Act, 1961 against the order dated 22.12.2023 passed in IT(TP)A No.32/CHNY/2022 on the file of Income Tax Appellate Tribunal 'D' Bench, Chennai. For Appellant : Mr.R.Karthik For Respondent : Mr.T.Banusekar ____________ Page 1 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 12/09/2025 08:52:59 pm ) TCA No.173 of 2025 JUDGMENT (Judgment of the Court was delivered by the Hon'ble Chief Justice) At the outset, learned counsel for appellant fairly submits 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 v. Sutherland Global Services Inc. [(2025) 175 taxmann.com 897 (Madras)]. 2. In that view of the matter, the appeal does not have any substantial question of law for consideration. Accordingly, appeal is dismissed at the admission stage. There shall be no order as to costs. Consequently, the interim application is also dismissed. (MANINDRA MOHAN SHRIVASTAVA, CJ) (G.ARUL MURUGAN,J)

10.09.2025 Index : Yes/No Neutral Citation : Yes/No kpl ____________ Page 2 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 12/09/2025 08:52:59 pm ) TCA No.173 of 2025 To 1. The Assistant Registrar Income Tax Appellate Tribunal Chennai. 2. The Assistant Commissioner of Income Tax International Taxation -2(2) Chennai. ____________ Page 3 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 12/09/2025 08:52:59 pm ) TCA No.173 of 2025 THE HON'BLE CHIEF JUSTICE AND G.ARUL MURUGAN,J. (kpl)

TCA No.173 of 2025

10.09.2025 ____________ Page 4 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 12/09/2025 08:52:59 pm )

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