Commissioner Of Income Tax vs. SMRC Automotive Holding Netherlands B.V.

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TCA/48/2025HC Madras30 July 2025Bench: Honourable The CHIEF JUSTICE4 pages
AI SummaryWithdrawn

What did the High Court hold?

The High Court held that the appeal filed by the Revenue was not maintainable because it did not meet the monetary limit prescribed by the CBDT Circular No.09/2024. The learned counsel for the Revenue fairly conceded this point. Consequently, the appeal was closed. The reasoning is based on the binding nature of the CBDT circular regarding monetary limits for appeals. The ratio decidendi is that appeals filed by the Revenue below the stipulated monetary threshold are liable to be dismissed or closed without a decision on merits. The operative direction was to close the appeal and consequently, the related miscellaneous applications (CMP Nos.10843 and 11154 of 2025). No issue was expressly left undecided.

What were the facts?

The appeal was filed by the Commissioner of Income Tax, International Taxation, Chennai (Revenue) against an order of the Income Tax Appellate Tribunal, Madras “D” Bench, Chennai, dated 22.12.2023 in IT(TP)A.No.53/CHNY/2021. The respondent is M/s. SMRC Automotive Holding Netherlands B.V. The High Court of Judicature at Madras was hearing the appeal. The assessment years are not specified in the provided text. The dispute pertains to an order passed by the ITAT. The procedural history involves the Revenue filing an appeal before the High Court.

What were the issues?

The High Court had to decide whether the appeal filed by the Revenue should be entertained. The Revenue's contention, as conceded by its learned counsel, was 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. The judgment does not record any specific arguments from the Respondent (assessee). The core issue revolves around the applicability of the monetary limit for filing appeals by the Revenue.

AI-generated summary — verify with the full judgment below

TCA No.48 of 2025 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 30.07.2025 CORAM THE HON'BLE MR.MANINDRA MOHAN SHRIVASTAVA, CHIEF JUSTICE AND THE HON'BLE MR.JUSTICE SUNDER MOHAN TCA No.48 of 2025 Commissioner Of Income Tax International Taxation Chennai- 600 034 : Appellant Vs M/s.SMRC Automotive Holding Netherlands B.V. C/o.SRMC Automotive Products India Ltd Plot No.G 34, Survey No.15 Pt 16Pt Siocot Incdustiral Park Vallam Vadagal A Village Kanchipuram 602 105 PAN AAHCR 3869C : Respondent Prayer: Appeal filed against the order of the Income Tax Appellate Tribunal, Madras “D” Bench, Chennai, dated 22.12.2023 in IT(TP)A.No.53/CHNY/2021. For Appellant : Mr.R.Karthik For Respondent : Mr.N.V.Narayanan Page 1 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 04/08/2025 05:58:07 pm ) TCA No.48 of 2025 JUDGMENT (Delivered by the Hon'ble Chief Justice) Learned counsel for the Revenue fairly conceded today 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. 2. The appeal is therefore closed. There will be no order as to costs. Consequently, CMP Nos.10843 and 11154 of 2025 are closed. (MANINDRA MOHAN SHRIVASTAVA, CJ.) (SUNDER MOHAN, J.) 30.07.2025 Index : Yes/No Neutral Citation : Yes/No tar Page 2 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 04/08/2025 05:58:07 pm ) TCA No.48 of 2025 To 1.The Commissioner Of Income Tax International Taxation Chennai- 600 034 2.The Income Tax Appellate Tribunal, Madras “D” Bench, Chennai Page 3 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 04/08/2025 05:58:07 pm ) TCA No.48 of 2025 THE HON'BLE CHIEF JUSTICE AND SUNDER MOHAN

, J.

(tar) TCA No.48 of 2025 30.07.2025 Page 4 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 04/08/2025 05:58:07 pm )

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