THE PR. COMMISSIONER OF INCOME TAX vs. CHOLAMANDALAM FINANCIAL HOLDINGS LIMITED

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TCA/295/2023HC Madras03 July 2025Bench: Honourable The CHIEF JUSTICE4 pages
AI SummaryWithdrawn

What did the High Court hold?

The High Court noted that the Revenue's counsel, Mrs. V. Pushpa, stated that the monetary limit involved in the appeal was below the limits prescribed by CBDT Circulars No. 05/2024 and 09/2024. Acting on instructions, the counsel sought to withdraw the appeal. The court was informed that the withdrawal was solely due to the monetary limit and not an admission of the Department's stand. Consequently, the appeal was dismissed as withdrawn. No order as to costs was made. The specific findings of the ITAT or the grounds on which the appeal was filed are not discussed or decided upon by the High Court.

What were the facts?

The appeal was filed by the Principal Commissioner of Income Tax, Chennai, against an order dated 24.06.2022 passed by the Income Tax Appellate Tribunal (ITAT), Madras 'A' Bench, Chennai. The respondent is M/s. Cholamandalam Financial Holdings Limited (formerly known as TI Financial Holdings Ltd.). The appeal was filed under Section 260A of the Income Tax Act, 1961. The specific assessment year(s) and the amount in dispute are not explicitly stated in the provided text. The procedural history leading to the ITAT order is not detailed.

What were the issues?

1. Whether the appeal, filed by the Revenue, is maintainable given the monetary limits prescribed by CBDT Circulars? (Question of law) Assessee's Contention: The Revenue's counsel stated that the monetary limit involved in this appeal is below the prescribed limits in 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. Based on instructions, the counsel sought to withdraw the appeal. Revenue's Contention: The Revenue's counsel explicitly stated the reason for withdrawal was the monetary limit, without conceding the stand of the Department. No specific arguments on the merits of the ITAT's order were presented.

Which sections of the Income-tax Act were involved?

Section 260A

AI-generated summary — verify with the full judgment below

T.C.A.No.295 of 2023 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 03.07.2025 CORAM : THE HON'BLE MR.K.R.SHRIRAM, CHIEF JUSTICE AND THE HON'BLE MR.JUSTICE SUNDER MOHAN T.C.A.No.295 of 2023 The Principal Commissioner of Income Tax Chennai. .. Appellant Vs. M/s.Cholamandalam Financial Holdings Limited (formerly known as TI Financial Holdings Ltd.) “Dare House”, No.234, NSC Bose Road Chennai 600 001 PAN: AAACT1249H .. Respondent Prayer : Appeal filed under Section 260A of the Income Tax Act, 1961 against the order dated 24.06.2022 passed in ITA No.2659/CHNY/2019 on the file of the Income Tax Appellate Tribunal, Madras 'A' Bench, Chennai. For Appellant : Mrs.V.Pushpa Senior Standing Counsel For Respondent : Mr.R.Venkat Narayanan For M/s. Subbaraya Aiyar Padmanabhan & Ramamani __________ Page 1 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 10/07/2025 11:33:08 am ) T.C.A.No.295 of 2023 JUDGMENT (Judgment of the Court was delivered by the Hon'ble Chief Justice) Ms.Pushpa states that the monetary limit involved in this appeal is below the monetary limit prescribed in 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. Counsel says that she has instructions, therefore, to withdraw the appeal. 2. Counsel also states that the withdrawal is only due to the monetary limit and without conceding the stand of the Department. 3. Appeal stands dismissed as withdrawn. There shall be no order as to costs. (K.R.SHRIRAM, CJ) (SUNDER MOHAN,J.)

03.07.2025 Index : Yes/No Neutral Citation : Yes/No __________ Page 2 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 10/07/2025 11:33:08 am ) T.C.A.No.295 of 2023 kpl To 1. The Assistant Registrar Income Tax Appellate Tribunal Chennai Benches, Chennai. 2. The Commissioner of Income Tax (Appeals) Chennai. 3. The Deputy Commissioner of Income Tax Large Taxpayer Unit Chennai.

__________ Page 3 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 10/07/2025 11:33:08 am ) T.C.A.No.295 of 2023 THE HON'BLE CHIEF JUSTICE AND SUNDER MOHAN

,J.

(kpl)

T.C.A.No.295 of 2023

03.07.2025 __________ Page 4 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 10/07/2025 11:33:08 am )

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