The Pr.Commissioner of Income Tax - 8, vs. Tamil Nadu Co-operative State Agriculture and Rura

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TCA/372/2022HC Madras26 August 2025Bench: Honourable The CHIEF JUSTICE4 pages
AI SummaryDismissed

What did the High Court hold?

The High Court, in view of the submission made by the learned counsel for the Revenue that the case has a low tax effect and that the Revenue does not wish to proceed with the matter in light of Circular No.05/2024 and Circular No.09/2024, dismissed the appeal. The Court noted that the Revenue requested that the questions of law be kept open for consideration in an appropriate matter. The operative direction was that the appeal stands dismissed with no order as to costs. No specific issue was left undecided as the appeal was dismissed on the grounds of low tax effect and the Revenue's decision not to press it.

What were the facts?

The appeal was filed by the Principal Commissioner of Income Tax - 8, Chennai (Revenue) against the order dated 29.04.2022 passed by the Income Tax Appellate Tribunal ('D' Bench, Chennai) in ITA No.32/CHNY/2021. The respondent is Tamil Nadu Co-operative State Agriculture and Rural Development Bank Limited. The appeal was filed under Section 260A of the Income Tax Act, 1961. The High Court heard both the learned counsel for the appellant/Revenue and the respondent/assessee.

What were the issues?

1. Whether the appeal filed by the Revenue should be dismissed on the grounds of low tax effect, considering the circulars issued by the CBDT. The Revenue, through its counsel, submitted that this is a case with a low tax effect. Therefore, 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. However, the Revenue requested that the questions of law be kept open for consideration in an appropriate matter. The assessee's contentions 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.372 of 2022 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.372 of 2022 Principal Commissioner of Income Tax - 8 Chennai. .. Appellant Vs. Tamil Nadu Co-operative State Agriculture and Rural Development Bank Limited No.181, Luz Church Road Mylapore Chennai 600 004 PAN: AABAT7344J .. Respondent Prayer : Appeal filed under Section 260A of the Income Tax Act, 1961 against the order dated 29.04.2022 passed in ITA No.32/CHNY/2021 on the file of Income Tax Appellate Tribunal 'D' Bench, Chennai. ____________ Page 1 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 28/08/2025 05:40:11 pm ) TCA No.372 of 2022 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. 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. ____________ Page 2 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 28/08/2025 05:40:11 pm ) TCA No.372 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)

26.08.2025 Index : Yes/No Neutral Citation : Yes/No kpl To 1. The Assistant Registrar Income Tax Appellate Tribunal “D” Bench, Chennai. 2. The Commissioner of Income Tax (Appeals)-2 Chennai. 3. The Assistant/Deputy Commissioner of Income Tax Chennai. ____________ Page 3 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 28/08/2025 05:40:11 pm ) TCA No.372 of 2022 THE HON'BLE CHIEF JUSTICE AND SUNDER MOHAN,J. (kpl)

TCA No.372 of 2022

26.08.2025 ____________ Page 4 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 28/08/2025 05:40:11 pm )

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