THE COMMISSIONER OF INCOME TAX vs. SHREE AMBIGA SUGARS LTD

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TCA/19/2021HC Madras09 January 2026Bench: Honourable The CHIEF JUSTICE4 pages
AI SummaryDismissed

What did the High Court hold?

The High Court noted the submission by the Revenue's counsel that the case has a low tax effect. Consequently, in light of Circular No.05/2024 and Circular No.09/2024, the Revenue expressed its unwillingness to pursue the appeal further, while reserving the right to have the question of law considered in a future, more appropriate case. Based on this submission from the Revenue, the High Court dismissed the appeal. No specific findings were made on the merits of the case, as the appeal was disposed of on procedural grounds related to tax effect and departmental policy. The operative direction was to dismiss the appeal, with no order as to costs.

What were the facts?

The appeal was filed by the Commissioner of Income Tax, Chennai (Revenue) against the order dated 27.09.2019 passed by the Income Tax Appellate Tribunal (ITAT), Madras 'C' Bench, Chennai. The assessee is M/s. Shree Ambiga Sugars Limited, and the assessment year in question is 2010-11. The appeal was filed under Section 260A of the Income Tax Act, 1961. The High Court heard the learned counsel for the appellant/Revenue and the respondent/Assessee.

What were the issues?

The judgment does not explicitly frame specific questions of law for the Tribunal to decide. However, the context of an appeal under Section 260A implies that the appeal would typically concern substantial questions of law arising from the ITAT's order. The Revenue, through its counsel, submitted that this is a case with a low tax effect. The Revenue stated that in view of 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, it does not wish to proceed with the matter, though the question of law may be kept open for consideration in an appropriate matter. 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.19 of 2021 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 09.01.2026 CORAM THE HON'BLE MR.MANINDRA MOHAN SHRIVASTAVA, CHIEF JUSTICE AND THE HON'BLE MR.JUSTICE G.ARUL MURUGAN TCA No.19 of 2021 The Commissioner of Income Tax, Chennai. .. Appellant -vs- M/s.Shree Ambiga Sugars Limited Eldarado, 5th Floor, 112, Mahatma Gandhi Road, Chennai 600 034. PAN: AABCS5163J .. Respondent Prayer: Appeal filed under Section 260A of the Income Tax Act, 1961, against the order dated 27.09.2019 passed in ITA No.1764/Chny/2019 on the file of the Income Tax Appellate Tribunal, Madras “C” Bench, Chennai, for the Assessment Year 2010-11. For Appellant : Mrs.V.Pushpa Senior Standing Counsel For Respondent : Mr.R.Vijaya Raghavan for M/s.Subbaraya Aiyar Padmanabhan & Ramamani * * * * * Page 1 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 12/01/2026 07:07:36 pm ) TCA No.19 of 2021 JUDGMENT (Delivered by the Hon'ble Chief Justice) Heard learned counsel for the appellant/Revenue. Mr.Vijayaraghavan,

learned

counsel,

appears

for

the respondent/Assessee. 2. At the outset, learned counsel for the Revenue fairly submits that it is a case 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 question of law may be kept open for consideration in the appropriate matter. In that view of the matter, the appeal stands dismissed. There shall be no order as to costs. (MANINDRA MOHAN SHRIVASTAVA, CJ.) (G.ARUL MURUGAN, J.) 09.01.2026 Index : Yes/No Neutral Citation : Yes/No sra Page 2 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 12/01/2026 07:07:36 pm ) TCA No.19 of 2021 To 1. The Income Tax Appellate Tribunal, Madras ‘C’ Bench, Chennai. 2. The Commissioner of Income Tax, Chennai. Page 3 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 12/01/2026 07:07:36 pm ) TCA No.19 of 2021 THE HON'BLE CHIEF JUSTICE AND G.ARUL MURUGAN, J. (sra) TCA No.19 of 2021 09.01.2026 Page 4 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 12/01/2026 07:07:36 pm )

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