THE COMMISSIONER OF INCOME TAX vs. M/S. SUNDARAM FINANCE LTD.,

TCA/334/2021HC Madras18 December 2025Bench: Honourable The CHIEF JUSTICE3 pages

AI SummaryDismissed

What did the High Court hold?

The High Court noted the submission by the Revenue that the case had a low tax effect. 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 appellant/Revenue stated that it did not wish to proceed with the matter. The Court acknowledged that the questions of law proposed could be kept open for consideration in an appropriate matter. Consequently, the appeal was dismissed. No order as to costs was made.

What were the facts?

The appeal was filed by the Commissioner of Income Tax, Chennai (Revenue) against an order dated 31.03.2017 passed by the Income Tax Appellate Tribunal (ITAT) 'B' Bench, Chennai, in ITA No. 284/Mds/2015. The respondent is M/s. Sundaram Finance Ltd. The appeal was filed under Section 260A of the Income Tax Act, 1961. The High Court heard learned counsel for both the appellant (Revenue) and the respondent (assessee). The Revenue stated that the case had a low tax effect.

What were the issues?

1. Whether the appeal should be dismissed on the grounds of low tax effect, as per CBDT Circulars No. 05/2024 and 09/2024. Contentions: Assessee: Not recorded. Revenue: The Revenue, through its counsel, submitted that due to the low tax effect, it did not wish to proceed with the matter, while requesting that the questions of law be kept open for consideration in an appropriate future case. This submission was made in light 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.

Which sections of the Income-tax Act were involved?

Section 260A

AI-generated summary — verify with the full judgment below

T.C.A. No.334 of 2021 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 18.12.2025 CORAM THE HONOURABLE MR. MANINDRA MOHAN SHRIVASTAVA, CHIEF JUSTICE AND THE HONOURABLE MR.JUSTICE G.ARUL MURUGAN T.C.A. No.334 of 2021 The Commissioner of Income Tax, Chennai. Appellant(s) Vs M/s.Sundaram Finance Ltd., 21, Pattulos Road, Chennai - 600 002. PAN: AAACS4944A Respondent(s) PRAYER: Appeal filed under Section 260A of the Income Tax Act, 1961 against the order dated 31.03.2017 passed in ITA 284/Mds/2015 on the file of Income Tax Appellate Tribunal ‘B’ Bench, Chennai. For Appellant(s) : Mrs.V.Pushpa Senior Standing Counsel For Respondent(s) : Mr.R.Venkatanarayanan for M/s.Subbaraya Aiyar Padmanabhan and Ramamani ___________ Page 1 of 3 https://www.mhc.tn.gov.in/judis ( Uploaded on: 19/12/2025 07:10:21 pm ) T.C.A. No.334 of 2021 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. 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. 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) 18.12.2025 Index : Yes/No Neutral Citation : Yes/No sri/mka ___________ Page 2 of 3 https://www.mhc.tn.gov.in/judis ( Uploaded on: 19/12/2025 07:10:21 pm ) T.C.A. No.334 of 2021 THE HON'BLE CHIEF JUSTICE AND G.ARUL MURUGAN,J. sri/mka T.C.A

. No.

334 of 2021

18.12.2025 ___________ Page 3 of 3 https://www.mhc.tn.gov.in/judis ( Uploaded on: 19/12/2025 07:10:21 pm )

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