The Principal Commissioner of Income Tax-3 vs. SUNDRAM FASTENERS LTD

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TCA/64/2026HC Madras02 June 2026Bench: Honourable The CHIEF JUSTICE4 pages
AI SummaryDismissed

What did the High Court hold?

The High Court noted the submission of the learned counsel for the Revenue that the cases have a low tax effect. In light of Circular No.05/2024 dated 15.03.2024 and Circular No.09/2024 dated 17.09.2024, issued by the Central Board of Direct Taxes, the Revenue expressed its unwillingness to proceed with the appeals. The Revenue also requested that the questions of law be kept open for future consideration. Consequently, the High Court dismissed the appeals. The specific findings of the ITAT on the merits of the case were not discussed or decided by the High Court, as the appeals were disposed of on the basis of the Revenue's submission regarding low tax effect and the relevant circulars. No operative directions were issued other than the dismissal of the appeals.

What were the facts?

The appeals were filed by the Principal Commissioner of Income Tax-3, Chennai (Revenue) against the orders of the Income Tax Appellate Tribunal (ITAT) dated 16.06.2023 in ITA Nos.74/Chny/2018 and 317/Chny/2018. The respondent in both appeals is Sundram Fasteners Ltd. The appeals were filed under Section 260A of the Income Tax Act, 1961. The specific assessment years and the amounts in dispute were not explicitly stated in the provided text. The procedural history involves the Revenue filing these appeals before the High Court after the ITAT passed its orders.

What were the issues?

1. Whether the appeals filed by the Revenue raise substantial questions of law for consideration by the High Court, as contemplated under Section 260A of the Income Tax Act, 1961. Contentions of the Revenue: The learned counsel for the Revenue submitted that the cases have a low tax effect. 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 does not wish to proceed with the matters. However, the Revenue requested that the questions of law may be kept open for consideration in an appropriate matter. Contentions of the Assessee: No arguments were recorded for the assessee in the provided judgment.

Which sections of the Income-tax Act were involved?

Section 260A

AI-generated summary — verify with the full judgment below

T.C.A.Nos.64 & 65 of 2026 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 02.06.2026 CORAM : THE HONOURABLE MR. SUSHRUT ARVIND DHARMADHIKARI, CHIEF JUSTICE AND THE HONOURABLE MR.JUSTICE G.ARUL MURUGAN T.C.A.Nos.64 & 65 of 2026 The Principal Commissioner of Income Tax-3 Chennai-600034. Appellant(s) Vs Sundram Fasteners Ltd 98-A,7th Floor, Dr.Radhakrishnan Salai Mylapore Chennai-600004 (PAN AAACS 8779D) Respondent(s) Prayer : Petitions filed under Section 260A of the Income Tax Act, 1961 against the order of the Income Tax Appellate Tribunal ‘D’ Bench dated 16.06.2023 in ITA No.74/Chny/2018 and 16.06.2023 passed in ITA No.317/Chny/2018 respectively. For Appellant(s): Mrs. V.Pushpa Senior Standing Counsel __________ Page 1 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 03/06/2026 05:20:21 pm ) T.C.A.Nos.64 & 65 of 2026 JUDGMENT (Judgment of the Court was 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 these cases are 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 matters, though the questions of law may be kept open for consideration in the appropriate matter. 3. In that view of the matter, the appeals stand dismissed. (SUSHRUT ARVIND DHARMADHIKARI,CJ) (G.ARUL MURUGAN,J)

02.06.2026 Index : Yes/No Neutral Citation : Yes/No kpl __________ Page 2 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 03/06/2026 05:20:21 pm ) T.C.A.Nos.64 & 65 of 2026 To 1. The Assistant Registrar Income Tax Appellate Tribunal Chennai Benches Chennai. 2. The Commissioner of Income Tax (Appeals)-15 121, Mahatma Gandhi Road Chennai 600 034. 3. The Deputy Commissioner of Income Tax Corporate Circle-6(2) Chennai.

__________ Page 3 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 03/06/2026 05:20:21 pm ) T.C.A.Nos.64 & 65 of 2026 THE HON'BLE CHIEF JUSTICE AND G.ARUL MURUGAN,J. (kpl) T.C.A.Nos.64 & 65 of 2026

02.06.2026 __________ Page 4 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 03/06/2026 05:20:21 pm )

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