THE COMMISSIONER OF INCOME TAX vs. M/S.SHRIRAM CAPITAL LTD

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TCA/191/2015HC Madras04 March 2026Bench: Honourable Dr Justice G. JAYACHANDRAN4 pages
AI SummaryWithdrawn

What did the High Court hold?

The High Court disposed of the appeals based on the assessee's submission regarding the monetary limit for appeals and the Revenue's statement that it was not interested in pursuing the appeals. The Court noted that the disputed tax was below the monetary limit for preferring further appeals as per Circular No. 9/2024. The Revenue's learned Standing Counsel, on instructions, confirmed the Department's lack of interest in pursuing the appeals. Consequently, the appeals were disposed of on these grounds. However, the Court explicitly stated that the substantial question of law raised in these appeals was left open. No order as to costs was made.

What were the facts?

The Revenue filed these five appeals (TCA Nos. 191 to 195 of 2015) before the High Court of Judicature at Madras, aggrieved by the orders dated 24.06.2011 passed by the Income Tax Appellate Tribunal (ITAT), Chennai. The appeals pertained to assessment years not specified in the judgment. The assessee, M/s. Shriram Capital Ltd (subsequently known as Shriram Financial Services Holdings Pvt Ltd) and M/s. Shriram Capital Trust Pvt Ltd, filed a memo stating that the disputed tax was below the monetary limit for further appeal as per Circular No. 9/2024. The Revenue's learned Standing Counsel, on instructions, stated that the Department was not interested in pursuing the appeals further.

What were the issues?

1. Whether the appeals filed by the Revenue are sustainable in light of the CBDT's monetary limit for filing appeals, as per Circular No. 9/2024? (Question of law) 2. Whether the Revenue is interested in pursuing the appeals further? (Question of fact/procedure) Assessee's Contention: The assessee contended that the disputed tax amount fell below the monetary limit prescribed by Circular No. 9/2024, rendering the appeals unsustainable. Revenue's Contention: The Revenue, through its learned Standing Counsel, stated on instructions that it was not interested in pursuing the appeals further.

AI-generated summary — verify with the full judgment below

TCA No. 191 of 2015 __________ Page1 of 4 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 04-03-2026 CORAM THE HON'BLE DR JUSTICE G. JAYACHANDRAN AND THE HON'BLE MR.JUSTICE SHAMIM AHMED TCA Nos. 191 to 195 of 2015 The Commissioner Of Income Tax Chennai ..Appellant-All TCAs Vs 1.M/s.Shriram Capital Ltd Seubsequently Known As Shriram Financial Services Holdings Pvt Ltd, Mookambika Complex 4, Lady Desika Rd, Mylapore Ch 4 ..Respondent-TCA.191 of 2015 2. M/s.Shriram Capital Trust P Ltd, 4, Mookambika Complex , Lady Desika Rd, Mylapore Ch 4 ..Respondent-TCA.192 to 195 of 2015 For Appellant(s): Mr..J.Narayanaswamy For Respondent(s): Mr.R.Sivaraman Judgment (Judgment of the Court was delivered by Dr.G.Jayachandran J.) 1. The Revenue has filed these Appeals, being aggrieved by the orders, dated 24.06.2011, passed by the Income Tax Appellate Tribunal, Chennai, in https://www.mhc.tn.gov.in/judis ( Uploaded on: 06/03/2026 01:21:27 pm ) TCA No. 191 of 2015 __________ Page2 of 4 ITA.Nos.1513/Mds/2010, 1514/Mds/2010, 1515/Mds/ 2010, 1516/Mds/ 2010 and 1517/Mds/2010, respectively. 2. The assessee, who is the Respondent, has filed a memo, stating that the disputed tax is below the monetary limit for preferring further appeal, as per the Circular No.9/2024 (F.No.279/Misc./M-74/2024-ITJ and in view of the said circular, these appeals are not sustainable. 3. On instructions, the learned Standing Counsel for the Appellant Department states that the Department is not interested in pursuing the appeals further. 4. In view of the said Circular and the submissions of the learned Standing Counsel for the Appellant, recording the same, these Appeals are disposed of. However, the substantial question of law raised in these appeals is left open. There is no order as to costs. (G.J.,J.) (S.S.A.,J.) 04-03-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No SRCM https://www.mhc.tn.gov.in/judis ( Uploaded on: 06/03/2026 01:21:27 pm ) TCA No. 191 of 2015 __________ Page3 of 4 DR.G.JAYACHANDRAN J. AND SHAMIM AHMED J. SRCM TCA No. 191 of 2015 AND TCA NO. 195 OF 2015,TCA NO. 194 OF 2015,TCA NO. 192 OF 2015,TCA NO. 193 OF 2015 04-03-2026 https://www.mhc.tn.gov.in/judis ( Uploaded on: 06/03/2026 01:21:27 pm ) TCA No. 191 of 2015 __________ Page4 of 4 TCA No. 191 of 2015 To M/s.Shriram Capital Ltd Seubsequently Known As Shriram Financial Services Holdings Pvt Ltd, Mookambika Complex 4, Lady Desika Rd, Mylapore Ch 4 TCA No. 195 of 2015 To M/s.Shriram Capital Trust P Ltd, 4, Mookambika Complex , Lady Desika Rd, Mylapore Ch 4 TCA No. 194 of 2015 To M/s.Shriram Capital Trust P Ltd, 4, Mookambika Complex , Lady Desika Rd, Mylapore Ch 4 TCA No. 192 of 2015 To M/s.Shriram Capital Trust P Ltd, 4, Mookambika Complex , Lady Desika Rd, Mylapore Ch 4 TCA No. 193 of 2015 To M/s.Shriram Capital Trust P Ltd, No.4, Mookambika Complex , Lady Desika Rd, Mylapore Ch 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 06/03/2026 01:21:27 pm )

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