THE COMMISSIONER OF INCOME TAX vs. HYUNDAI MOTOR INDIA LTD.,

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TCA/612/2021HC Madras10 July 2025Bench: Honourable The CHIEF JUSTICE4 pages
AI SummaryWithdrawn

What did the High Court hold?

The High Court of Judicature at Madras, comprising the Hon'ble Chief Justice K.R. Shriram and Justice Sunder Mohan, noted that the Revenue's counsel had instructions to withdraw the appeals. The withdrawal was stated to be solely due to the monetary limits prescribed by recent CBDT circulars and not an admission of the Department's stand on merits. Consequently, the Court ordered that the appeals stand dismissed as withdrawn. No order as to costs was made. The interim applications connected to these appeals were also dismissed.

What were the facts?

The Commissioner of Income Tax, Chennai (the Revenue) filed three appeals (T.C.A.Nos.612, 619 & 623 of 2021) before the High Court of Judicature at Madras against orders passed by the Income Tax Appellate Tribunal, Madras 'D' Bench, Chennai. The appeals were filed under Section 260A of the Income Tax Act, 1961. The respondent in these appeals is M/s. Hyundai Motor India Ltd. The appeals challenged the Tribunal's orders dated 27.04.2017. The procedural history involves the filing of these appeals and connected interim applications.

What were the issues?

1. Whether the appeals filed by the Revenue are maintainable in light of the monetary limits prescribed by CBDT Circulars. (Question of law) Assessee's Contention: The Revenue's counsel, Mrs. V. Pushpa, stated that the monetary limits involved in these appeals were below the prescribed limits in Circular Nos.612, 619 & 623 of 202105/2024 dated 15.03.2024 and Circular Nos.612, 619 & 623 of 202109/2024, dated 17.09.2024, issued by the Ministry of Finance, Department of Revenue, Central Board of Direct Taxes. She further stated that she had instructions to withdraw the appeals on this ground. Revenue's Contention: Not applicable as the Revenue's counsel sought to withdraw the appeals.

Which sections of the Income-tax Act were involved?

Section 260A

AI-generated summary — verify with the full judgment below

T.C.A.Nos.612, 619 & 623 of 2021

IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 10.07.2025 CORAM : THE HON'BLE MR.K.R.SHRIRAM, CHIEF JUSTICE AND THE HON'BLE MR.JUSTICE SUNDER MOHAN T.C.A.Nos.612, 619 & 623 of 2021 & C.M.P.Nos.21606, 21705 & 21750 of 2021 The Commissioner of Income Tax Appellant in Chennai. .. all TCAs. Vs. M/s. Hyundai Motor India Ltd. Plot No.H-1, SIPCOT Industrial Park Irungattukottai, Sriperumbudur Taluk Kancheepuram 602 117 Respondent in PAN: AAACH2364M .. all TCAs. Prayer : Appeals under Section 260A of the Income Tax Act, 1961 against the order dated 27.04.2017 passed in ITA Nos.739/Mds/2014, 761/Mds/2016 & 614/Mds/2015 on the file of the Income Tax Appellate Tribunal, Madras 'D' Bench, Chennai. For Appellant : Mrs.V.Pushpa For Respondent : Mr.S.P.Chidambaram __________ Page 1 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 14/07/2025 04:27:38 pm ) T.C.A.Nos.612, 619 & 623 of 2021

JUDGMENT (Judgment of the Court was delivered by the Hon'ble Chief Justice) Ms.Pushpa states that the monetary limit involved in these appeals are below the monetary limit prescribed in Circular Nos.612, 619 & 623 of 202105/2024 dated 15.03.2024 and Circular Nos.612, 619 & 623 of 202109/2024, dated 17.09.2024, issued by the Ministry of Finance, Department of Revenue, Central Board of Direct Taxes, Government of India. Counsel says that she 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. 3. Appeals stand dismissed as withdrawn. There shall be no order as to costs. Consequently, the interim applications are also dismissed. (K.R.SHRIRAM, CJ) (SUNDER MOHAN,J.)

10.07.2025 Index : Yes/No __________ Page 2 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 14/07/2025 04:27:38 pm ) T.C.A.Nos.612, 619 & 623 of 2021

Neutral Citation : Yes/No kpl To 1. The Assistant Registrar Income Tax Appellate Tribunal Chennai Benches, Chennai. 2. The Commissioner of Income Tax (Appeals) Chennai.

__________ Page 3 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 14/07/2025 04:27:38 pm ) T.C.A.Nos.612, 619 & 623 of 2021

THE HON'BLE CHIEF JUSTICE AND SUNDER MOHAN

,J.

(kpl)

T.C.A.Nos.612, 619 & 623 of 2021

10.07.2025 __________ Page 4 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 14/07/2025 04:27:38 pm )

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