COMMISSIONER OF INCOEM TAX vs. M/S. NATCHIAR TEXTILES

TCA/236/2016HC Madras15 April 2026Bench: Honourable Dr Justice G. JAYACHANDRAN3 pages

AI SummaryWithdrawn

What did the High Court hold?

The High Court held that the Tax Case Appeal filed by the Revenue is dismissed as withdrawn. This decision is based on Circular No.9 of 2024 issued by the Central Board of Direct Taxes, which prescribes a monetary limit of Rs.2 crores for filing appeals by the Revenue before the High Court. Since the tax effect involved in the present appeal is Rs.1,59,78,300/-, which is less than Rs.2 crores, the appeal is not maintainable under the said circular. The Court granted liberty to the Revenue to raise the substantial question of law in an appropriate case. No costs were awarded. The substantive issues decided by the ITAT were not examined by the High Court.

What were the facts?

The Revenue, Commissioner of Income Tax, Virudhunagar Circle, filed a Tax Case Appeal under Section 260A of the Income Tax Act, 1961, challenging an order of the Income Tax Appellate Tribunal, Chennai, dated 30.09.2015 in ITA No.1625/Mds/2015. The assessee is M/s Natchiar Textiles Exporters. The disputed tax liability in this case amounts to Rs.1,59,78,300/-. The appeal was filed against the order of the ITAT.

What were the issues?

1. Whether the Tax Case Appeal filed by the Revenue is maintainable before the High Court given the monetary limit prescribed by CBDT Circular No.9 of 2024? (Question of law). The Revenue argued that the appeal should be heard on merits. The Revenue did not present any arguments on the substantive issue of the appeal, as the appeal itself was dismissed based on the monetary limit. The judgment does not record any specific arguments from the assessee regarding the maintainability of the appeal, other than implicitly accepting the Revenue's withdrawal.

Which sections of the Income-tax Act were involved?

Section 260A

AI-generated summary — verify with the full judgment below

IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 15.04.2026 CORAM THE HONOURABLE DR. JUSTICE G. JAYACHANDRAN AND THE HONOURABLE MR.JUSTICE R.SAKTHIVEL T.C.A.No.236 of 2016 Commissioner of Income Tax, Virudhunagar Circle, Virudhunagar. ..Appellant/Appellant /versus/ M/s Natchiar Textiles Exporters 547/15, Rajapalayam Road, Chatrapatti 626 102, PAN:AAAFN7765P ..Respondent/Respondent Tax Case Appeal has been filed under Section 260A of the Income Tax Act, 1961, against the order of the Income Tax Appellate Tribunal, “C” Bench, Chennai dated 30.09.2015 in ITA No.1625/Mds/2015. For Appellant :Mr.V.Mahalingam, Sr.St.C. For Respondent :Mr.S.Sridhar, 1/3 https://www.mhc.tn.gov.in/judis ( Uploaded on: 17/04/2026 05:43:07 pm ) JUDGMENT (Judgment of the Court was delivered by Dr.G.Jayachandran,J.) Challenging the order passed by the Income Tax Appellate Tribunal in ITA.No.1625/Mds/2015 dated 30.09.2015, the Revenue has preferred the present appeal. 2.The disputed tax liability in the present case is Rs.1,59,78,300/-. As per Circular No.9 of 2024 dated 17.09.2024 issued by the Central Board of Direct Taxes, the monetary limit prescribed for filing appeals by the Revenue before this Court is Rs.2 crores. Since the tax effect involved in this appeal is less than Rs.2 crores and in view of the circular No.9 of 2024, this Tax Case Appal is dismissed as withdrawn, with liberty to the Revenue to raise the substantial question of law in an appropriate case. No costs. (Dr.G.JAYACHANDRAN,J.) (R.SAKTHIVEL,J.)

15.04.2026 ari Index:yes/no Neutral citation:yes/no 2/3 https://www.mhc.tn.gov.in/judis ( Uploaded on: 17/04/2026 05:43:07 pm ) Dr.G. JAYACHANDRAN,J. AND R.SAKTHIVEL, J. ari T.C.A.No.236 of 2016 15.04.2026 3/3 https://www.mhc.tn.gov.in/judis ( Uploaded on: 17/04/2026 05:43:07 pm )

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