The Pr Commissioner of Income Tax-1 vs. Lakshmanan

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TCA/305/2023HC Madras26 August 2025Bench: Honourable The CHIEF JUSTICE4 pages
AI SummaryDismissed

What did the High Court hold?

The High Court noted the submission by the learned counsel for the Revenue that the case has a low tax effect. In light of this submission and in accordance with Circular No.05/2024 and Circular No.09/2024 issued by the Ministry of Finance, Department of Revenue, Central Board of Direct Taxes, the Revenue stated its intention not to proceed with the matter. The Court acknowledged that the questions of law may be kept open for consideration in other matters. Consequently, the appeal filed by the Revenue was dismissed. No specific findings were made on the merits of the case or the issues that might have been raised by the Tribunal's order. 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 - 1, Chennai (the Revenue) against an order dated 18.11.2022 passed by the Income Tax Appellate Tribunal ('A' Bench, Chennai). The appeal was filed under Section 260A of the Income Tax Act, 1961. The respondent is Lakshmanan (the assessee). The specific assessment year(s) and the amount in dispute are not explicitly stated in the provided text. The procedural history leading to the Tribunal's order is also not detailed.

What were the issues?

The judgment does not explicitly frame specific questions of law for determination. However, the appeal by the Revenue implicitly raises issues concerning the correctness of the Income Tax Appellate Tribunal's order dated 18.11.2022. The Revenue's primary contention, as presented in the judgment, is that the case has a low tax effect. Consequently, the Revenue, citing Circular No.05/2024 dated 15.03.2024 and Circular No.09/2024 dated 17.09.2024, does not wish to proceed with the appeal, while seeking to keep the questions of law open for consideration in other appropriate matters. The assessee's arguments 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

TCA No.305 of 2023 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 26.08.2025 CORAM : THE HONOURABLE MR. MANINDRA MOHAN SHRIVASTAVA, CHIEF JUSTICE AND THE HONOURABLE MR.JUSTICE SUNDER MOHAN TCA No.305 of 2023 Principal Commissioner of Income Tax - 1 Chennai. .. Appellant Vs. Lakshmanan .. Respondent Prayer : Appeal filed under Section 260A of the Income Tax Act, 1961 against the order dated 18.11.2022 passed in ITA No.2744/CHNY/2019 on the file of Income Tax Appellate Tribunal 'A' Bench, Chennai. For Appellant : Mr.T.Ravikumar Senior Standing Counsel For Respondent : Mr.G.Baskar JUDGMENT (Judgment of the Court was delivered by the Hon'ble Chief Justice) Heard learned counsel for the appellant/Revenue and learned counsel for the respondent/assessee. ____________ Page 1 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 28/08/2025 05:40:10 pm ) TCA No.305 of 2023 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 may be kept open for consideration in the appropriate matter. 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)

26.08.2025 Index : Yes/No Neutral Citation : Yes/No kpl ____________ Page 2 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 28/08/2025 05:40:10 pm ) TCA No.305 of 2023 To 1. The Assistant Registrar Income Tax Appellate Tribunal “A” Bench, Chennai. 2. The Commissioner of Income Tax (Appeals) - 2 Chennai. 3. The Income Tax Officer Non-Corporate Ward-1(3) Chennai. ____________ Page 3 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 28/08/2025 05:40:10 pm ) TCA No.305 of 2023 THE HON'BLE CHIEF JUSTICE AND SUNDER MOHAN,J. (kpl)

TCA No.305 of 2023

26.08.2025 ____________ Page 4 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 28/08/2025 05:40:10 pm )

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