PRINCIPAL COMMISSIONER OF INCOME TAX vs. YENNARKAY R. CHIRANJEEVIRATHNAM
What did the High Court hold?
The High Court noted the submission by the Revenue's counsel that the case involves a low tax effect. Citing Circular No.05/2024 dated 15.03.2024 and Circular No.09/2024 dated 17.09.2024, issued by the CBDT, the Revenue stated its intention not to pursue the appeal further, while requesting that the question of law be preserved for future cases. Consequently, the High Court dismissed the appeal. No specific finding was made on the merits of the original appeal before the Tribunal. The principle derived is that appeals with low tax effect may be withdrawn by the Revenue based on its administrative instructions, without prejudice to the legal question for other matters. The operative direction was the dismissal of the appeal.
What were the facts?
This case involves an appeal filed by the Principal Commissioner of Income Tax, Madurai (the Revenue) against an order dated 23.11.2022 passed by the Income Tax Appellate Tribunal, Madras 'A' Bench, Chennai. The appeal pertains to the Assessment Year 2010-11 and challenges the Tribunal's decision. The Revenue's counsel made a submission at the outset of the hearing. The assessee is Yennarkay R. Chiranjeevirathnam.
What were the issues?
1. Whether the appeal filed by the Revenue under Section 260A of the Income Tax Act, 1961, should be proceeded with, considering the low tax effect and relevant CBDT circulars. Assessee's Contentions: Not recorded in the judgment. Revenue's Contentions: The Revenue's counsel submitted that the case has a low tax effect. 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, the Revenue does not wish to proceed with the matter. However, the Revenue requested that the question of law be kept open for consideration in an appropriate matter.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
TCA No.245 of 2023 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 19.09.2025 CORAM THE HON'BLE MR.MANINDRA MOHAN SHRIVASTAVA, CHIEF JUSTICE AND THE HON'BLE MR.JUSTICE G.ARUL MURUGAN TCA No.245 of 2023 Principal Commissioner of Income Tax Madurai. .. Appellant -vs- Yennarkay R.Chiranjeevirathnam .. Respondent Prayer: Appeal filed under Section 260A of the Income Tax Act, 1961, against the order dated 23.11.2022 passed in ITA No.219/Chny/2020 on the file of the Income Tax Appellate Tribunal, Madras “A” Bench, Chennai, for the Assessment Year 2010-11. For Appellant : Mr.V.Mahalingam Senior Standing Counsel and Mr.P.E.R.Mangala Suvigaran, Junior Standing Counsel For Respondent : Mr.A.S.Sriraman Page 1 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 22/09/2025 06:52:21 pm ) TCA No.245 of 2023 JUDGMENT (Delivered by the Hon'ble Chief Justice) Heard learned counsel for the appellant/Revenue. Mr.Sriraman, 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.) 19.09.2025 Index : Yes/No Neutral Citation : Yes/No sra Page 2 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 22/09/2025 06:52:21 pm ) TCA No.245 of 2023 To 1. The Income Tax Appellate Tribunal, Madras 'A' Bench, Chennai. 2. The Principal Commissioner of Income Tax, Madurai. Page 3 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 22/09/2025 06:52:21 pm ) TCA No.245 of 2023 THE HON'BLE CHIEF JUSTICE AND G.ARUL MURUGAN
, J.
(sra) TCA No.245 of 2023 19.09.2025 Page 4 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 22/09/2025 06:52:21 pm )
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