Commissioner Of Income Tax vs. Laserwords Us Inc

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TCA/47/2025HC Madras10 June 2025Bench: Honourable The CHIEF JUSTICE4 pages
AI SummaryWithdrawn

What did the High Court hold?

The High Court of Judicature at Madras held that the appeal was to be dismissed as withdrawn. The Court noted that the appellant's counsel informed the Court that the monetary limit involved in the appeal was below the limit prescribed in Circular No.09/2024, dated 17.09.2024, issued by the Ministry of Finance, Department of Revenue, Central Board of Direct Taxes. Consequently, the counsel had instructions to withdraw the appeal. The Court further noted that the withdrawal was only due to the monetary limit and without conceding the stand of the Department. The appeal was accordingly dismissed as withdrawn, with no order as to costs. The interim applications were also closed.

What were the facts?

The appeal was filed by the Commissioner of Income Tax (International Taxation), Chennai, against an order of the Income Tax Appellate Tribunal (ITAT), 'D' Bench, Chennai, dated 22.12.2023 in IT(TP)A No.34/CHNY/2023. The respondent is Laserwords US Inc. The appeal was filed under Section 260A of the Income Tax Act, 1961. The High Court of Judicature at Madras was hearing the appeal. The appellant's counsel stated that the monetary limit involved in the appeal was below the prescribed limit in Circular No.09/2024 dated 17.09.2024, issued by the CBDT. Consequently, the counsel had instructions to withdraw the appeal.

What were the issues?

1. Whether the appeal filed by the Revenue is maintainable given the monetary limit prescribed by CBDT Circular No.09/2024? The Revenue, through its counsel, argued that the monetary limit involved in the appeal was below the threshold stipulated in CBDT Circular No.09/2024, dated 17.09.2024. Based on this, the counsel stated they had instructions to withdraw the appeal. The Revenue also clarified that the withdrawal was solely due to the monetary limit and did not involve conceding the Department's stand on merits. The Assessee's contentions 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

TCA No.47 of 2025 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 10.06.2025 CORAM : THE HON'BLE MR.K.R.SHRIRAM, CHIEF JUSTICE AND THE HON'BLE MR.JUSTICE SUNDER MOHAN TCA No.47 of 2025 CMP Nos.5215 and 5218 of 2025 Commissioner of Income Tax International Taxation Chennai - 600 034. Appellant(s) Vs Laserwords US Inc., C/o.SPI Technologies India Pvt Ltd Gothi Industrial Estate RS Nos.415 and 416 Vazhuduvur Road Kurumbapet Revenue Village Puducherry – 605 009. Respondent(s) Prayer: Appeal filed under Section 260A of the Income Tax Act, 1961 against the order of the Income Tax Appellate Tribunal “D” Bench, Chennai, __________ Page 1 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 12/06/2025 04:00:32 pm ) TCA No.47 of 2025 dated 22.12.2023 in IT(TP)A No.34/CHNY/2023. For Appellant(s): Mr.R.Karthik, Sr.Standing Counsel For Respondent(s): Mr.N.V.Balaji JUDGMENT (Delivered by the Hon'ble Chief Justice) Mr.Karthik states that the monetary limit involved in this appeal is below the monetary limit prescribed in 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. Counsel says that he has instructions, therefore, to withdraw the appeal. 2. Counsel also states that the withdrawal is only due to the monetary limit and without conceding the stand of the Department. Appeal stands dismissed as withdrawn. There shall be no order as to costs. Consequently, interim applications stand closed. (K.R.SHRIRAM, CJ.) (SUNDER MOHAN, J.)

10.06.2025 __________ Page 2 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 12/06/2025 04:00:32 pm ) TCA No.47 of 2025 Index : Yes/No Neutral Citation : Yes/No sasi To: 1. The Assistant Registrar Income Tax Appellate Tribunal Chennai Benches, Chennai. 2. The Income Tax Officer (OSD) & Secretary (DRP-1) Office of Dispute Resolution Panel-1 Kendriya Sadan, 4th Floor, C Wing Bengaluru – 560 034. 3. The Deputy Commissioner of Income Tax Office of the Assistant Commissioner of Income Tax International Taxation, DCIT INTL Tax 1(2) Chennai. __________ Page 3 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 12/06/2025 04:00:32 pm ) TCA No.47 of 2025 THE HON'BLE CHIEF JUSTICE AND SUNDER MOHAN,J. (sasi)

TCA No.47 of 2025

10.06.2025 __________ Page 4 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 12/06/2025 04:00:32 pm )

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