PRINCIPAL COMMISSIONER OF INCOME TAX vs. ST JOHN FREIGHT SYSTEM PRIVATE LIMITED

TCA/465/2023HC Madras19 August 2025Bench: Honourable The CHIEF JUSTICE4 pages

AI SummaryDismissed

What did the High Court hold?

The High Court, upon hearing the learned counsel for both the appellant/Revenue and the respondent/assessee, noted the submission by the Revenue that the case had a low tax effect. In light of this submission and 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, the Revenue expressed its unwillingness to proceed with the appeal. The Court accepted this position and accordingly dismissed the appeal. The questions of law were expressly left open for consideration in an appropriate matter. No order as to costs was made.

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.188/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 Revenue, through its counsel, submitted that the case had a low tax effect. Consequently, in view of Circular No.05/2024 dated 15.03.2024 and Circular No.09/2024 dated 17.09.2024 issued by the CBDT, the Revenue did not wish to proceed with the matter, while reserving the right to have the questions of law considered in an appropriate future case.

What were the issues?

1. Whether the appeal filed by the Revenue should be dismissed on the grounds of low tax effect, as per the CBDT Circulars? Assessee's Contention: The assessee did not explicitly present arguments in the judgment. However, the Revenue's submission implies that the appeal is being withdrawn due to low tax effect, aligning with the spirit of the CBDT circulars which are intended to streamline litigation and reduce the burden on taxpayers and the judiciary in cases with insignificant financial implications. Revenue's Contention: The Revenue, through its learned counsel, submitted that the case has 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 appellant/Revenue does not wish to proceed with the matter. The Revenue also stated that the questions of law proposed may be kept open for consideration in an appropriate matter.

Which sections of the Income-tax Act were involved?

Section 260A

AI-generated summary — verify with the full judgment below

T.C.A.No.465 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.465 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.188/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.465 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.465 of 2023 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)

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.465 of 2023 THE HON'BLE CHIEF JUSTICE AND SUNDER MOHAN,J. bbr

TCA No.465 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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