COMMISSIONER OF INCOME TAX vs. M/S RAMCO INDUSTRIES LTD.,

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TCA/59/2018HC Madras22 September 2025Bench: Honourable The CHIEF JUSTICE4 pages
AI SummaryDismissed

What did the High Court hold?

The High Court noted the submission of the Revenue's counsel regarding the low tax effect of the case. In light of the relevant circulars issued by the Central Board of Direct Taxes (Circular No.05/2024 and Circular No.09/2024), the Revenue expressed its unwillingness to proceed with the appeal. The Court acknowledged that the question of law could be preserved for future consideration. Based on the Revenue's submission and the cited circulars, the High Court decided to dismiss the appeal. The principle derived is that appeals with low tax effect may be withdrawn or dismissed based on administrative instructions from the CBDT, even if a question of law is involved, provided the Revenue so chooses and the question is left open for future adjudication.

What were the facts?

This matter concerns an appeal filed by the Commissioner of Income Tax, Corporate Circle-2, Madurai (the Revenue) against an order dated 26.10.2016 passed by the Income Tax Appellate Tribunal, Madras 'A' Bench, Chennai. The appeal pertains to Assessment Year 2008-09 and challenges the Tribunal's decision in ITA No.2163/MDS/2015. The assessee is M/s. Ramco Industries Limited. The appeal was filed under Section 260A of the Income Tax Act, 1961. The High Court heard the learned counsel for the appellant/Revenue.

What were the issues?

The primary issue before the High Court was whether to proceed with the appeal. The Revenue, represented by its counsel, submitted that the case has a low tax effect. Consequently, the Revenue, 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, Government of India, did not wish to pursue the matter further. The Revenue also stated that the question of law may be kept open for consideration in an appropriate future matter. The judgment does not record any specific arguments from the assessee.

Which sections of the Income-tax Act were involved?

Section 260A

AI-generated summary — verify with the full judgment below

TCA No.59 of 2018 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 22.09.2025 CORAM THE HON'BLE MR.MANINDRA MOHAN SHRIVASTAVA, CHIEF JUSTICE AND THE HON'BLE MR.JUSTICE G.ARUL MURUGAN TCA No.59 of 2018 Commissioner of Income Tax Corporate Circle-2, Madurai. .. Appellant -vs- M/s.Ramco Industries Limited, No.47, PSK Nagar, Rajapalayam, PAN: AAACR5284J .. Respondent Prayer: Appeal filed under Section 260A of the Income Tax Act, 1961, against the order dated 26.10.2016 passed in ITA No.2163/MDS/2015 on the file of the Income Tax Appellate Tribunal, Madras “A” Bench, Chennai, for the Assessment Year 2008-09. For Appellant : Mr.V.Mahalingam Senior Standing Counsel and Mr.P.E.R.Mangala Suvigaran, Junior Standing Counsel * * * * * Page 1 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 23/09/2025 04:39:40 pm ) TCA No.59 of 2018 JUDGMENT (Delivered by the Hon'ble Chief Justice) Heard learned counsel for the appellant/Revenue. 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 question of law may be kept open for consideration in the appropriate matter. In that view of the matter, the appeal stands dismissed. There shall be no order as to costs. (MANINDRA MOHAN SHRIVASTAVA, CJ.) (G.ARUL MURUGAN, J.) 22.09.2025 Index : Yes/No Neutral Citation : Yes/No sra Page 2 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 23/09/2025 04:39:40 pm ) TCA No.59 of 2018 To 1. The Income Tax Appellate Tribunal, Madras 'A' Bench, Chennai. 2. The Commissioner of Income Tax, Corporate Circle-2, Madurai. Page 3 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 23/09/2025 04:39:40 pm ) TCA No.59 of 2018 THE HON'BLE CHIEF JUSTICE AND G.ARUL MURUGAN

, J.

(sra) TCA No.59 of 2018 22.09.2025 Page 4 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 23/09/2025 04:39:40 pm )

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