THE COMMISSIONER INCOME TAX vs. M/S PANASONIC LIFE SOLUTIONS PRIVATE LIMITED

TCA/555/2016HC Madras01 September 2025Bench: Honourable The CHIEF JUSTICE4 pages

AI SummaryWithdrawn

What did the High Court hold?

The High Court disposed of the appeals filed by the Revenue. The decision was based on the statement made by the learned counsel for the respondent/assessee, confirming that the assessee had already availed the benefits under the 'Vivad se Vishwas Scheme' concerning the tax liability for Assessment Years 2008-09 and 2009-10. Furthermore, the assessee's appeals had already been withdrawn. Consequently, the Revenue's appeals were also disposed of. The Court, however, explicitly stated that the questions of law were kept open for consideration in an appropriate future case. No order as to costs was made, and the interim applications were closed.

What were the facts?

The appeals were filed by the Commissioner of Income Tax, Chennai (Revenue) against the common order dated 09.03.2016 passed by the Income Tax Appellate Tribunal (ITAT), Madras 'D' Bench, Chennai. The appeals pertained to Assessment Years (AYs) 2008-09 and 2009-10. The respondent in these appeals is M/s. Panasonic Life Solutions Private Limited. The High Court noted that the assessee had availed benefits under the 'Vivad se Vishwas Scheme' for the tax liabilities relating to the disputed assessment years. Consequently, the appeals filed by the assessee had already been withdrawn.

What were the issues?

1. Whether the appeals filed by the Revenue should be dismissed in light of the assessee having availed benefits under the 'Vivad se Vishwas Scheme' and having withdrawn its own appeals. (Question of law) Assessee's Contention: The assessee, through its counsel, stated that it had availed the benefits under the 'Vivad se Vishwas Scheme' for the tax liability pertaining to AYs 2008-09 and 2009-10, and that its appeals before the Tribunal had already been withdrawn. Based on this submission, the assessee would implicitly argue that the Revenue's appeals are rendered infructuous or should be disposed of accordingly. Revenue's Contention: The judgment does not record any specific arguments made by the Revenue. However, by filing the appeals, the Revenue would have sought to press its grounds against the ITAT's order.

AI-generated summary — verify with the full judgment below

TCA Nos.555 and 556 of 2016 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 01.09.2025 CORAM THE HON'BLE MR.MANINDRA MOHAN SHRIVASTAVA, CHIEF JUSTICE AND THE HON'BLE MR.JUSTICE G.ARUL MURUGAN TCA Nos.555 and 556 of 2016 and CMP Nos.11037 and 8284 of 2016 The Commissioner of Income Tax, Chennai. .. Appellant in both appeals -vs- M/s.Panasonic Life Solutions Private Limited, 12th Floor, Ambience Towers, Ambience Island, NH-8, Gurgaon 122001. (Cause title amended vide court order dated 28.04.2025 made in CMP.Nos.10031 and 10039 of 2025 in TCA Nos.555 and 556 of 2016). .. Respondent in both appeals Prayer: Appeals filed against the common order dated 09.03.2016 passed in I.T.A.Nos.476/Mds/2015 and 477/Mds/2015 on the file of the Income Tax Appellate Tribunal, Madras “D” Bench, Chennai, for the Assessment Years 2008-09 and 2009-10. For Appellant in both appeals : Mr.D.Prabhu Mukunth Arun Kumar Senior Standing Counsel For Respondent in both appeals : Ms.Niveditha R.Mehta Page 1 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 03/09/2025 04:07:35 pm ) TCA Nos.555 and 556 of 2016 * * * * * JUDGMENT (Delivered by the Hon'ble Chief Justice) Taking into consideration the statement made on behalf of the learned counsel for the respondent/assessee that the assessee has already availed the benefits under the 'Vivad se Vishwas Scheme' , in relation to the tax liability relating to Assessment Year 2008-09 and 2009-10 and the appeals filed by the assessee have already been withdrawn, these appeals filed by the Revenue also stand disposed of, however, keeping open the questions of law for being considered in appropriate case. There shall be no order as to costs. Consequently, the interim applications stand closed. (MANINDRA MOHAN SHRIVASTAVA, CJ.) (G.ARUL MURUGAN, J.) 01.09.2025 Index : Yes/No Neutral Citation : Yes/No sra Page 2 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 03/09/2025 04:07:35 pm ) TCA Nos.555 and 556 of 2016 To 1. The Income Tax Appellate Tribunal, Madras 'D' Bench, Chennai. 2. The Commissioner of Income Tax, Chennai. Page 3 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 03/09/2025 04:07:35 pm ) TCA Nos.555 and 556 of 2016 THE HON'BLE CHIEF JUSTICE AND G.ARUL MURUGAN

, J.

(sra) TCA Nos.555 and 556 of 2016 01.09.2025 Page 4 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 03/09/2025 04:07:35 pm )

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