THE Pr.COMMISSIONER OF INCOME TAX vs. M/S. A.P. SRIDHAR (HUF)

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TCA/307/2022HC Madras28 August 2025Bench: Honourable The CHIEF JUSTICE4 pages
AI SummaryDismissed

What did the High Court hold?

The High Court noted the submission of 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 expressed its unwillingness to pursue the appeal. Consequently, the High Court dismissed the appeal. The Court explicitly stated that the question of law, though not decided on merits, would be kept open for consideration in an appropriate matter. No order as to costs was made. The judgment does not provide any specific findings on the merits of the original dispute before the ITAT, nor does it detail the reasoning of the ITAT.

What were the facts?

This appeal was filed by the Principal Commissioner of Income Tax-I, Chennai (the Revenue) against an order of the Income Tax Appellate Tribunal, Madras A Bench, Chennai, dated 23.02.2022, passed in I.T.A.No. 2735/Chny/2016. The assessee is A.P.Sridhar (HUF). The appeal was filed under Section 260A of the Income Tax Act. The judgment does not specify the assessment year(s) or the amount in dispute. The procedural history leading to the ITAT order is not detailed in this judgment.

What were the issues?

1. Whether the appeal raises a substantial question of law concerning the order of the Income Tax Appellate Tribunal dated 23.02.2022 in I.T.A.No. 2735/Chny/2016. Assessee's Contentions: Not recorded. Revenue's Contentions: The Revenue, through its learned counsel, conceded that the case has a low tax effect. Relying on 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 submitted that it did not wish to proceed with the matter, while requesting that the question of law be kept open for consideration in an appropriate future case.

Which sections of the Income-tax Act were involved?

Section 260A

AI-generated summary — verify with the full judgment below

TCA.No.307 of 2022 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 28.08.2025 CORAM : THE HONOURABLE MR. MANINDRA MOHAN SHRIVASTAVA, CHIEF JUSTICE AND THE HONOURABLE MR.JUSTICE SUNDER MOHAN TCA No. 307 of 2022 The Principal Commissioner of Income Tax-I Chennai. Appellant(s) Vs A.P.Sridhar (HUF) Newry Shobika, Flat No.2, 1st Floor, New No.3, Chimmaiah Pillai Street, T. Nagar, Chennai - 600 017. Respondent(s) PRAYER

: Appeal filed under Section 260A of the Income Tax Act against the order of Income Tax Appellate Tribunal, Madras A Bench, Chennai dated 23.02.2022 passed in I.T.A.No. 2735/Chny/2016. ______________ Page 1 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 03/09/2025 08:56:53 pm ) TCA.No.307 of 2022 For Appellant(s): Mr.T.Ravi Kumar For Respondent(s): 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 question of law may be kept open for consideration in the appropriate matter. ______________ Page 2 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 03/09/2025 08:56:53 pm ) TCA.No.307 of 2022 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)

28.08.2025 Index : Yes/No Neutral Citation : Yes/No sasi To: 1. The Registrar Income Tax Appellate Tribunals Chennai. 2. The Deputy Commissioner of Income Tax Business Circle-II, Chennai. 3. The Commissioner of Income Tax (Appeals)-2 Chennai. ______________ Page 3 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 03/09/2025 08:56:53 pm ) TCA.No.307 of 2022 THE HON'BLE CHIEF JUSTICE AND SUNDER MOHAN,J. (sasi)

TCA No. 307 of 2022

28.08.2025 ______________ Page 4 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 03/09/2025 08:56:53 pm )

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