COMMISSIONER OF INCOME TAX vs. M/S. UCAL FUEL SYSTEMS LTD

TCA/669/2017HC Madras17 July 2025Bench: Honourable The CHIEF JUSTICE4 pages

AI SummaryWithdrawn

What did the High Court hold?

The High Court noted that the counsel for the appellant (Revenue) stated that the monetary limit involved in the appeals was below the prescribed limits in recent circulars from the Ministry of Finance. Consequently, the counsel had instructions to withdraw the appeals. The withdrawal was explicitly stated to be due to the monetary limit and without conceding the Department's stand. Therefore, the Court ordered the appeals to be dismissed as withdrawn. No order as to costs was made. The judgment does not record any decision on the merits of the original appeals before the ITAT.

What were the facts?

The appeals were filed by the Commissioner of Income Tax, Company Circle – 3(2), Chennai, against M/s. Ucal Fuel Systems Limited. The appeals were filed under Section 260A of the Income Tax Act, 1961, challenging the orders dated 21.10.2016 passed by the Income Tax Appellate Tribunal ('D' Bench, Chennai) in ITA Nos.688/MDS/2014, 723/MDS/2015, and 725/MDS/2015. The appeals were listed for hearing before the High Court of Judicature at Madras.

What were the issues?

The primary issue before the High Court was whether the appeals filed by the Revenue should be proceeded with. The Revenue, through its counsel, stated that the monetary limit involved in these appeals was below the limits prescribed in 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's counsel indicated they had instructions to withdraw the appeals. The assessee's contentions, if any, are not recorded in the judgment. No specific legal questions were framed or debated as the appeals were withdrawn.

Which sections of the Income-tax Act were involved?

Section 260A

AI-generated summary — verify with the full judgment below

T.C.A.Nos.669, 670 & 672 of 2017

IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 17.07.2025 CORAM : THE HON'BLE MR.K.R.SHRIRAM, CHIEF JUSTICE AND THE HON'BLE MR.JUSTICE SUNDER MOHAN T.C.A.Nos.669, 670 & 672 of 2017 Commissioner of Income Tax Company Circle – 3(2) Appellant in Chennai. .. all TCAs. Vs. M/s. Ucal Fuel Systems Limited Raheja Towers, 7th Floor, Unit 705 No.177, Anna Salai Chennai 600 002. Respondent in PAN: AAACU0541K .. all TCAs. Prayer : Appeals under Section 260A of the Income Tax Act, 1961 against the order dated 21.10.2016 in ITA Nos.688/MDS/2014, 723/MDS/2015 & 725/MDS/2015 on the file of Income Tax Appellate Tribunal 'D' Bench, Chennai. For Appellant : Mr.J.Narayanasamy Senior Standing Counsel For Respondent : Mr.A.S.Sriraman __________ Page 1 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 17/07/2025 08:44:04 pm ) T.C.A.Nos.669, 670 & 672 of 2017

JUDGMENT (Judgment of the Court was delivered by the Hon'ble Chief Justice) Mr.Narayanasamy states that the monetary limit involved in these appeals is below the monetary limit prescribed in 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. Counsel says that he has instructions, therefore, to withdraw the appeals. 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. (K.R.SHRIRAM, CJ) (SUNDER MOHAN,J.)

17.07.2025 Index : Yes/No Neutral Citation : Yes/No kpl __________ Page 2 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 17/07/2025 08:44:04 pm ) T.C.A.Nos.669, 670 & 672 of 2017

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: 17/07/2025 08:44:04 pm ) T.C.A.Nos.669, 670 & 672 of 2017

THE HON'BLE CHIEF JUSTICE AND SUNDER MOHAN

,J.

(kpl)

T.C.A.Nos.669, 670 & 672 of 2017

17.07.2025 __________ Page 4 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 17/07/2025 08:44:04 pm )

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