M/S.SERVIONT GLOBAL SOLUTIONS LTD vs. ASSISTANT COMMISSIONER OF INCOME TAX

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TCA/387/2021HC Madras12 November 2025Bench: Honourable The CHIEF JUSTICE4 pages
AI SummaryWithdrawn

What did the High Court hold?

The High Court noted the statement made by the learned counsel for the appellant that the assessee had opted for the Vivad Se Viswas Scheme, 2024 and had filed a declaration. Based on this statement, the appellant's counsel indicated that they did not wish to press the appeal. The Court accepted this submission and placed the statement on record. Consequently, the appeal was dismissed as withdrawn. The Court granted liberty to the appellant to pursue the remedy under the Vivad Se Viswas Scheme. No specific findings were made on the merits of the original appeal, and no issue was left undecided as the appeal was disposed of on a procedural ground. There were no operative directions other than dismissing the appeal as withdrawn with liberty.

What were the facts?

The appellant, Serviont Global Solutions Limited, filed an appeal under Section 260A of the Income-tax Act, 1961, against an order of the Income Tax Appellate Tribunal (ITAT), Madras “D” Bench, dated 28.12.2020 in IT(TP)A No.46/Chny/2019. The respondent is the Assistant Commissioner of Income Tax, Corporate Circle 6(1), Chennai. The appeal was heard by the High Court of Judicature at Madras. The specific assessment year(s) and the amount in dispute are not explicitly stated in the provided text. The procedural history leading to the High Court appeal involves the ITAT's order which is now under challenge.

What were the issues?

The High Court was to decide the appeal filed by the assessee against the ITAT's order. However, no specific questions of law or fact were framed or discussed in the provided judgment text. The judgment records a statement made by the learned counsel for the appellant. The appellant's counsel stated that the assessee had opted for the Vivad Se Viswas Scheme, 2024 for the relevant assessment year and had filed a declaration. Consequently, the appellant's counsel indicated that they did not wish to press the appeal and would pursue the remedy under the Vivad Se Viswas Scheme. The revenue's contentions are not recorded as the appeal was withdrawn before any substantive arguments were presented.

Which sections of the Income-tax Act were involved?

Section 260A

AI-generated summary — verify with the full judgment below

T.C.A.No.387 of 2021 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 12.11.2025 CORAM : THE HONOURABLE MR. MANINDRA MOHAN SHRIVASTAVA, CHIEF JUSTICE AND THE HONOURABLE MR.JUSTICE G.ARUL MURUGAN T.C.A.No.387 of 2021 Serviont Global Solutions Limited 4/600 & 4/197, 7th Street, Dr. VSI Estate, Phase II, Thiruvanmiyur, Chennai - 600 041 (PAN - AAACI0947F) Appellant Vs The Assistant Commissioner of Income Tax Corporate Circle 6(1), Chennai - 600 034. Respondent PRAYER

: Appeal filed under Section 260A of the Income-tax Act, 1961 against the order of the Income Tax Appellate Tribunal, Madras “D” Bench, dated 28.12.2020 in IT(TP)A No.46/Chny/2019. For Appellant: Ms.Sonali Kothari.S. for Mr.S.P.Chidambaram For Respondent: Mr.J.Narayanasamy Senior Standing Counsel ______________ Page 1 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 14/11/2025 02:33:03 pm ) T.C.A.No.387 of 2021 JUDGMENT (Order of the Court was made by the Hon'ble Chief Justice) Heard. 2. A statement is made by learned counsel for the appellant that the assessee opted for Vivad Se Viswas Scheme, 2024 for the relevant assessment year and also filed declaration and, therefore, she does not wish to press this appeal and shall pursue the remedy as above. 3. Placing the statement on record, the appeal is dismissed as withdrawn, with liberty to pursue the aforesaid remedy. There shall be no order as to costs. (MANINDRA MOHAN SHRIVASTAVA, CJ) (G.ARUL MURUGAN,J)

12.11.2025 Index : Yes/No Neutral Citation : Yes/No bbr ______________ Page 2 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 14/11/2025 02:33:03 pm ) T.C.A.No.387 of 2021 To: 1. The Assistant Registrar Income Tax Appellate Tribunal Chennai Benches, Chennai. 2. The Commissioner of Income Tax (Appeals)-15, Chennai. 3. The Assistant Commissioner of Income Tax, Corporation Circle 6(1), Chennai. ______________ Page 3 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 14/11/2025 02:33:03 pm ) T.C.A.No.387 of 2021 THE HON'BLE CHIEF JUSTICE AND G.ARUL MURUGAN,J. bbr

T.C.A.No.387 of 2021

12.11.2025 ______________ Page 4 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 14/11/2025 02:33:03 pm )

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