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

TCA/466/2023HC Madras19 August 2025Bench: Honourable The CHIEF JUSTICE4 pages

AI SummaryDismissed

What did the High Court hold?

The High Court noted the submission by the Revenue's counsel that the case had a low tax effect. In view of Circular No.05/2024 and Circular No.09/2024, issued by the Ministry of Finance, Department of Revenue, Central Board of Direct Taxes, the Revenue stated it did not wish to proceed with the appeal. Consequently, the High Court dismissed the appeal. The questions of law were expressly kept open for consideration in an appropriate matter. No order as to costs was made, and the connected miscellaneous petition was closed.

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 (ITAT) dated 06.04.2023 in ITA No.2900/Mds/2019. The respondent assessee 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 and the respondent.

What were the issues?

The judgment does not explicitly state the specific issues that were before the ITAT or the questions of law proposed by the Revenue for consideration by the High Court. However, the Revenue's counsel made a submission regarding the low tax effect of the case. The Revenue did not wish to proceed with the matter due to Circular No.05/2024 and Circular No.09/2024, although the questions of law were to be kept open. No arguments were recorded for the assessee regarding the substantive issues.

Which sections of the Income-tax Act were involved?

Section 260A

AI-generated summary — verify with the full judgment below

T.C.A.No.466 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.466 of 2023 and C.M.P.No.20092 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.2900/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.466 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.466 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.466 of 2023 THE HON'BLE CHIEF JUSTICE AND SUNDER MOHAN,J. bbr

TCA No.466 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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