THE COMMISSIONER OF INCOME vs. M/S WHEELS INDIA LTD

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TCA/452/2015HC Madras2026/MHC/412906 October 2026Bench: Honourable Dr.Justice ANITA SUMANTH4 pages
AI SummaryWithdrawn

What did the High Court hold?

The High Court recorded the submission of the Revenue that it did not wish to pursue the appeals due to low tax effect, citing Circular No. 9 of 2024. Consequently, the Court dismissed both Tax Case (Appeals) as withdrawn. The Court explicitly stated that the questions of law remain open to be decided in an appropriate future matter. No costs were awarded. The operative direction was the dismissal of the appeals as withdrawn.

What were the facts?

The appeals before the High Court of Judicature at Madras were filed by the Commissioner of Income Tax, Chennai, against the orders of the Income Tax Appellate Tribunal (ITAT), Madras Bench. TCA No. 452 of 2015 pertains to Assessment Year (AY) 2010-11, challenging the ITAT's order in ITA No. 383/Mds/2014. TCA No. 453 of 2015 relates to AY 2009-10, challenging the ITAT's order in ITA No. 394/Mds/2014. The appeals were filed under Section 260A of the Income-Tax Act, 1961. The respondent in both appeals is M/s Wheels India Ltd.

What were the issues?

The primary issue is whether the Income-Tax Department wishes to pursue the appeals. The Revenue, represented by Ms. V. Pushpa, learned Senior Standing Counsel, submitted that the Department does not wish to pursue these appeals for AY 2010-11 and AY 2009-10. This decision was based on a low tax effect, as per Circular No. 9 of 2024 dated 17.09.2024. The Assessee, M/s Wheels India Ltd, did not present any arguments as the Revenue sought withdrawal.

Which sections of the Income-tax Act were involved?

Section 260A

AI-generated summary — verify with the full judgment below

2026:MHC:4129 TCA Nos. 452 & 453 of 2015 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 06-10-2026 CORAM THE HON'BLE DR.JUSTICE ANITA SUMANTH AND THE HON'BLE MR.JUSTICE K.RAJASEKAR TCA No. 452 of 2015 CNR:{HCMA010512062015} AND TCA NO. 453 OF 2015 The Commissioner Of Income Tax, Chennai ..Appellant(s) Vs M/s Wheels India Ltd Padi Chennai 600 050 ..Respondent(s) TCA No. 453 of 2015 CNR:{HCMA010512112015} The Commissioner Of Income Tax, Chennai ..Appellant(s) Vs M/s Wheels India Ltd Padi Chennai 600 050 ..Respondent(s) __________ Page 1 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 08/10/2026 04:56:44 pm ) 2026:MHC:4129 TCA Nos. 452 & 453 of 2015 Prayer in TCA.No.452 of 2015: Tax Case (Appeal) filed under Section 260A of the Income-Tax Act, 1961 against the order of the Income Tax Appellate Tribunal Madras ‘’ Bench, Chennai dated 26.09.2014 in ITA No.383/Mds/2014 for the A.Y. 2010-11. Prayer in TCA.No.453 of 2015: Tax Case (Appeal) filed under Section 260A of the Income-Tax Act, 1961 against the order of the Income Tax Appellate Tribunal Madras ‘C’ Bench, Chennai dated 26.09.2014 in ITA No.394/Mds/2014 for the A.Y. 2009-10. In both TCA’S For Appellant(s): Ms. V. Pushpa, SSC For Respondent(s): Mr. R. Venkata Narayanan for M/s.Subbaraya Aiyar Padmanabhan and Ramamani Common Judgment (Judgment of the Court was delivered by Dr.Anita Sumanth J.) Ms. V. Pushpa, learned Senior Standing Counsel, appearing for the appellant / Department would submit that the Income-Tax Department does not wish to pursue these appeals qua assessment years 2010 – 2011 (TCA.No.452 of 2015) and 2009 – 2010 (TCA.No.453 of 2015) and seeks withdrawal of the same on account of low tax effect, per Circular bearing No.9 of 2024 dated 17.09.2024. __________ Page 2 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 08/10/2026 04:56:44 pm ) 2026:MHC:4129 TCA Nos. 452 & 453 of 2015 2. Recording the aforesaid submissions, these Tax Case (Appeals) are dismissed as withdrawn leaving the questions of law open to be decided in an appropriate matter. No costs. (A.S.M.,J.) (K.R.S.,J.) 06-10-2026 mpl Index: Yes/No Speaking order Neutral Citation: Yes To 1.The Income Tax Appellate Tribunal Madras ‘C’ Bench, Chennai. __________ Page 3 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 08/10/2026 04:56:44 pm ) 2026:MHC:4129 TCA Nos. 452 & 453 of 2015 DR.ANITA SUMANTH J. AND K.RAJASEKAR J. MPL TCA No. 452 of 2015 AND TCA NO. 453 OF 2015 06-10-2026 __________ Page 4 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 08/10/2026 04:56:44 pm )

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