Principal Commissioner of Income Tax vs. M/s.St John Freight System Private Ltd

TCA/464/2023HC Madras19 August 2025Bench: Honourable The CHIEF JUSTICE4 pages

AI SummaryDismissed

What did the High Court hold?

The High Court noted the submission of the Revenue that the case involves a low tax effect. Consequently, in light of Circular No.05/2024 and Circular No.09/2024, the Revenue expressed its unwillingness to pursue the appeal further. The Court accepted this submission and accordingly dismissed the appeal. The Court explicitly stated that the questions of law proposed may be kept open for consideration in an appropriate matter. No specific findings were made on the merits of the original dispute, as the appeal was disposed of on procedural grounds related to tax effect and departmental circulars. The operative direction was the dismissal of the appeal.

What were the facts?

The appeal was filed by the Principal Commissioner of Income Tax, Madurai (Revenue) against the order of the Income Tax Appellate Tribunal ("B" Bench, Chennai) dated 6.4.2023 in ITA No.2898/Mds/2019. The respondent is St. John Freight System Private Limited. The appeal was filed under Section 260A of the Income Tax Act, 1961. The High Court heard the learned counsel for both the appellant (Revenue) and the respondent (assessee). The Revenue stated that it is a case with a low tax effect.

What were the issues?

1. Whether the appeal, involving a low tax effect, should be proceeded with by the Revenue? The Revenue argued that 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, it does not wish to proceed with the matter, while reserving the right to have the questions of law considered in an appropriate future case. The assessee's arguments 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

T.C.A.No.464 of 2023 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 19.08.2025 CORAM : THE HONOURABLE MR. MANINDRA MOHAN SHRIVASTAVA, CHIEF JUSTICE AND THE HONOURABLE MR.JUSTICE SUNDER MOHAN T.C.A.No.464 of 2023 and C.M.P.No.20011 of 2023 The Principal Commissioner of Income Tax Madurai Appellant Vs St. John Freight System Private Limited C-98, SIPCOT Complex, Harbour Express Road, Tuticorin-628 008 Respondent Prayer: Appeal filed under Section 260A of the Income Tax Act, 1961 against the order of the Income Tax Appellate Tribunal “B” Bench, Chennai, dated 6.4.2023 in ITA No.2898/Mds/2019. ____________ Page 1 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 21/08/2025 05:53:11 pm ) T.C.A.No.464 of 2023 For Appellant: Mr.V.Mahalingam Sr. Standing Counsel For Respondent: Mr.R.Venkatanarayanan for M/s.Subbaraya Aiyar Padmanabhan Ramamani

JUDGMENT (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. ____________ Page 2 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 21/08/2025 05:53:11 pm ) T.C.A.No.464 of 2023 3. In that view of the matter, the appeal stands dismissed. There shall be no order as to costs. Consequently, connected miscellaneous petition is closed. (MANINDRA MOHAN SHRIVASTAVA, CJ) (SUNDER MOHAN,J)

19.08.2025 Index : Yes/No Neutral Citation : Yes/No bbr To: 1. The Assistant Registrar Income Tax Appellate Tribunal “B” Bench, Chennai. 2. The Commissioner of Income Tax (Appeals), Chennai-34. 3. The Deputy Commissioner of Income Tax, Central Circle-1, Madurai-2. ____________ Page 3 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 21/08/2025 05:53:11 pm ) T.C.A.No.464 of 2023 THE HON'BLE CHIEF JUSTICE AND SUNDER MOHAN,J. bbr

TCA No.464 of 2023

19.08.2025 ____________ Page 4 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 21/08/2025 05:53:11 pm )

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