THE COMMISSIONER OF INCOME TAX vs. M/S.ATLAS METAL PROCESSORS P LTD

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TCA/330/2020HC Madras16 September 2025Bench: Honourable The CHIEF JUSTICE4 pages
AI SummaryDismissed

What did the High Court hold?

The High Court noted the submission of the learned counsel for the Revenue that the case had a low tax effect. In light of Circular No.05/2024 and Circular No.09/2024, which guide the Revenue's decision to pursue appeals based on tax effect, the Revenue expressed its unwillingness to proceed with the matter. The Court accepted this submission. Therefore, the appeal filed by the Revenue was dismissed. The Court explicitly stated that the questions of law are kept open for consideration in an appropriate matter. No specific findings were made on the merits of the ITAT's order, as the dismissal was based on the Revenue's decision not to press the appeal due to low tax effect. 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 dated 23.12.2019 passed by the Income Tax Appellate Tribunal (ITAT), 'B-SMC' Bench, Chennai. The appeal was filed under Section 260A of the Income Tax Act, 1961. The respondent is M/s. Atlas Metal Processors P Ltd. The specific assessment year(s) and the amount in dispute are not explicitly stated in the provided text. The procedural history is limited to the Revenue filing this appeal against the ITAT's order.

What were the issues?

The primary issue before the High Court was whether to entertain the appeal filed by the Revenue. The Revenue, represented by its counsel, submitted that the case has a low tax effect. Consequently, 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 did not wish to proceed with the matter. The Revenue's contention was that due to the low tax effect and the extant circulars, they sought to withdraw from pursuing the appeal, while reserving the right to have the questions of law considered in an appropriate future matter. The judgment does not record any specific arguments from the assessee.

Which sections of the Income-tax Act were involved?

Section 260A

AI-generated summary — verify with the full judgment below

TCA No.330 of 2020 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 16.09.2025 CORAM : THE HONOURABLE MR. MANINDRA MOHAN SHRIVASTAVA, CHIEF JUSTICE AND THE HONOURABLE MR.JUSTICE G.ARUL MURUGAN TCA No.330 of 2020 The Commissioner of Income Tax Chennai. .. Appellant Vs. M/s. Atlas Metal Processors P Ltd. 29/69, Eldams Road Teynampet Chennai 600 018 PAN: AAACA7401Q .. Respondent Prayer : Appeal filed under Section 260A of the Income Tax Act, 1961 against the order dated 23.12.2019 passed in ITA No.1994/CHNY/2018 on the file of Income Tax Appellate Tribunal 'B-SMC' Bench, Chennai. For Appellant : Mr.T.Ravikumar Senior Standing Counsel ____________ Page 1 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 19/09/2025 04:53:42 pm ) TCA No.330 of 2020 JUDGMENT (Judgment of the Court was delivered by the Hon'ble Chief Justice) Heard learned counsel for the appellant/Revenue. 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) (G.ARUL MURUGAN,J)

16.09.2025 kpl ____________ Page 2 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 19/09/2025 04:53:42 pm ) TCA No.330 of 2020 To 1. The Assistant Registrar Income Tax Appellate Tribunal 'B-SMC' Bench, Chennai. 2. The Commissioner of Income Tax, Chennai.

____________ Page 3 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 19/09/2025 04:53:42 pm ) TCA No.330 of 2020 THE HON'BLE CHIEF JUSTICE AND G.ARUL MURUGAN,J. (kpl)

TCA No.330 of 2020

16.09.2025 ____________ Page 4 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 19/09/2025 04:53:42 pm )

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