COMMISSIONER OF INCOME TAX vs. SMT.HEMALATHA RAJAN

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TCA/59/2021HC Madras30 January 2026Bench: Honourable The CHIEF JUSTICE4 pages
AI SummaryDismissed

What did the High Court hold?

The High Court, upon hearing the submissions of the learned counsel for the appellant/Revenue, noted that the Revenue did not wish to proceed with the matter due to a low tax effect, as per Circular No.05/2024 and Circular No.09/2024. Consequently, the Court dismissed the appeal. The Court explicitly stated that the question of law would be kept open for consideration in an appropriate matter. No specific findings were made on the merits of the ITAT's order or the underlying tax dispute. The operative direction was the dismissal of the appeal, with no order as to costs.

What were the facts?

This case involves an appeal filed by the Commissioner of Income Tax (Revenue) against an order of the Income Tax Appellate Tribunal (ITAT), Chennai Bench, dated 17.10.2019 in ITA No.668/Chny/2019. The assessee is Hemalatha Rajan. The appeal was filed under Section 260A of the Income Tax Act, 1961. The Revenue, represented by its counsel, submitted at the outset that the case has a low tax effect. Consequently, 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, the Revenue did not wish to proceed with the matter.

What were the issues?

1. Whether the appeal filed by the Revenue should be dismissed on the grounds of low tax effect, as per the CBDT circulars? (Question of law) The Revenue's contention was that due to the low tax effect, it did not wish to proceed with the appeal, citing Circular No.05/2024 and Circular No.09/2024. The Revenue also stated that the question of law should be kept open for consideration in an appropriate matter. The judgment does not record any specific arguments from the assessee's side regarding the merits of the case or the applicability of the circulars.

Which sections of the Income-tax Act were involved?

Section 260A

AI-generated summary — verify with the full judgment below

TCA No.59 of 2021 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 30.01.2026 CORAM : THE HONOURABLE MR. MANINDRA MOHAN SHRIVASTAVA, CHIEF JUSTICE AND THE HONOURABLE MR.JUSTICE G.ARUL MURUGAN T.C.A.No.59 of 2021 The Commissioner of Income Tax Corporate Circle 4(1) Chennai Appellant Vs Hemalatha Rajan Flat No.C3, 3rd Floor, Golden Kings Court, No.61, Tas Enclave, 10th Main Road, Anna Nagar, Chennai 600 040 Respondent Prayer: Appeal filed under Section 260A of the Income Tax Act, 1961 against the order of the Income Tax Appellate Tribunal “C” Bench, Chennai, dated 17.10.2019 in ITA No.668/Chny/2019. ______________ Page 1 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 03/02/2026 01:22:17 pm ) TCA No.59 of 2021 For Appellant: Dr.S.Sathiyanarayanan Sr. Standing Counsel For Respondent: Ms.Sonali Kothari .S for Mr.S.P.Chidambaram JUDGMENT (Order of the Court was made by the Hon'ble Chief Justice) Heard. 2. Learned counsel for the appellant/Revenue, at the outset, 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. ______________ Page 2 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 03/02/2026 01:22:17 pm ) TCA No.59 of 2021 3. 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)

30.01.2026 Index : Yes/No Neutral Citation : Yes/No bbr To: 1. The Assistant Registrar Income Tax Appellate Tribunal “C” Bench, Chennai. 2. The Commissioner of Income-tax Appeals-8 Chennai. 3. The Dy. Commissioner of Income Tax Corporate Circle-4(1), Chennai. ______________ Page 3 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 03/02/2026 01:22:17 pm ) TCA No.59 of 2021 THE HON'BLE CHIEF JUSTICE AND G.ARUL MURUGAN,J. bbr T.C.A.No.59 of 2021

30.01.2026 ______________ Page 4 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 03/02/2026 01:22:17 pm )

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