THE COMMISSIONER OF INCOME vs. M/S. UCAL FUEL SYSTEMS LTD

TCA/267/2015HC Madras08 August 2025Bench: 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 had a low tax effect. In light of Circular No.05/2024 and Circular No.09/2024, the Revenue stated its intention not to pursue the appeal further. Consequently, the High Court dismissed the appeal. The court explicitly mentioned that the questions of law proposed by the Revenue would be kept open for consideration in an appropriate matter in the future. No decision was made on the merits of the case. The operative direction was the dismissal of the appeal.

What were the facts?

This case involves an appeal filed by the Commissioner of Income Tax, Chennai (the Revenue) against an order of the Income Tax Appellate Tribunal (ITAT), 'A' Bench, Chennai, dated 30.11.2011 in ITA No.1519/Mds/2011. The assessee is Ucal Fuel Systems Ltd. The appeal was filed under Section 260A of the Income Tax Act, 1961. The High Court of Judicature at Madras heard the appeal. The Revenue, through its counsel, made a submission regarding the low tax effect of the case.

What were the issues?

The High Court was to decide the appeal filed by the Revenue. The specific questions of law were not explicitly detailed in the provided judgment excerpt. However, the Revenue's counsel submitted that the case has a low tax effect. The Revenue, citing Circular No.05/2024 dated 15.03.2024 and Circular No.09/2024 dated 17.09.2024, indicated that they did not wish to proceed with the matter, while reserving the right to have the questions of law considered in future appropriate cases. 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

T.C.A.No.267 of 2015 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 08.08.2025 CORAM : THE HONOURABLE MR. MANINDRA MOHAN SHRIVASTAVA, CHIEF JUSTICE AND THE HONOURABLE MR.JUSTICE SUNDER MOHAN T.C.A.No.267 of 2015 The Commissioner of Income Tax Chennai Appellant Vs Ucal Fuel Systems Ltd., Raheja Towers, Delta Wing Unit 705 177, Anna Salai, Chennai-600 002 Respondent Prayer: Appeal filed under Section 260A of the Income Tax Act, 1961 against the order of the Income Tax Appellate Tribunal “A” Bench, Chennai, dated 30.11.2011 in ITA No.1519/Mds/2011. ____________ Page 1 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 11/08/2025 08:32:37 pm ) T.C.A.No.267 of 2015 For Appellant: Mr.J.Narayanasamy Sr. Standing Counsel For Respondent: Mr.S.Sridhar

JUDGMENT (Delivered by the Hon'ble Chief Justice) Heard learned counsel for the appellant/Revenue and learned counsel 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 questions of law proposed may be kept open for consideration in the appropriate matter. ____________ Page 2 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 11/08/2025 08:32:37 pm ) T.C.A.No.267 of 2015 3. In that view of the matter, the appeal stands dismissed. There shall be no order as to costs. (MANINDRA MOHAN SHRIVASTAVA, CJ) (SUNDER MOHAN,J)

08.08.2025 Index : Yes/No Neutral Citation : Yes/No bbr To: 1. The Assistant Registrar Income Tax Appellate Tribunal “A” Bench, Chennai. 2. The Commissioner of Income-tax Appeals-III Chennai. 3. The Joint Commissioner of Income Tax, Company Range-III, Chennai-34. ____________ Page 3 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 11/08/2025 08:32:37 pm ) T.C.A.No.267 of 2015 THE HON'BLE CHIEF JUSTICE AND SUNDER MOHAN,J. bbr

TCA No.267 of 2015

08.08.2025 ____________ Page 4 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 11/08/2025 08:32:37 pm )

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