Principal Commissioner of Income Tax vs. IFMR Rural Channels and Services P. Ltd

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TCA/73/2022HC Madras26 August 2025Bench: Honourable The CHIEF JUSTICE4 pages
AI SummaryDismissed

What did the High Court hold?

The High Court, in its judgment delivered by the Hon'ble Chief Justice, noted the submission of the learned counsel for the Revenue regarding the low tax effect and reliance on CBDT Circulars No. 05/2024 and 09/2024. Consequently, the Revenue expressed its unwillingness to pursue the appeal further. The Court accepted this submission and proceeded to dismiss the appeal. The Court explicitly stated that the questions of law would be kept open for consideration in an appropriate matter. No specific finding was made on the merits of the case, and no operative directions for remand or deletion were issued. The appeal was dismissed on procedural grounds as per the Revenue's request.

What were the facts?

The appeal was filed by the Principal Commissioner of Income Tax, Corporate Circle 2(2), Chennai (Revenue) against an order dated 29.09.2021 passed by the Income Tax Appellate Tribunal ('B' Bench, Chennai). The appeal was preferred by the Revenue under Section 260A of the Income Tax Act, 1961. The assessee is M/s. IFMR Rural Channels & Services P. Ltd. The specific assessment year(s) and the amount in dispute are not explicitly stated in the provided text. The procedural history involves the Revenue filing this appeal before the High Court after the ITAT's order.

What were the issues?

The primary issue before the High Court was whether to proceed with the appeal filed by the Revenue. The Revenue, through its counsel, submitted that the case has a low tax effect. The Revenue relied on 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. Based on these circulars, the Revenue stated it did not wish to proceed with the matter, while requesting that the questions of law be kept open for consideration in an appropriate future case. The assessee's contentions are not recorded in the judgment.

Which sections of the Income-tax Act were involved?

Section 260A

AI-generated summary — verify with the full judgment below

TCA No.73 of 2022 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 26.08.2025 CORAM : THE HONOURABLE MR. MANINDRA MOHAN SHRIVASTAVA, CHIEF JUSTICE AND THE HONOURABLE MR.JUSTICE SUNDER MOHAN TCA No.73 of 2022 Principal Commissioner of Income Tax Corporate Circle 2(2) Chennai 600 034. .. Appellant Vs. M/s. IFMR Rural Channels & Services P. Ltd. Phase-I, 10th Floor, IITM Research Park Kanagam Village (Behind Tidel Park) Taramani Chennai 600 113 PAN: AAFCR4450D .. Respondent Prayer : Appeal filed under Section 260A of the Income Tax Act, 1961 against the order dated 29.09.2021 passed in ITA No.2679/CHNY/2019 on the file of Income Tax Appellate Tribunal 'B' Bench, Chennai. ____________ Page 1 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 28/08/2025 05:40:11 pm ) TCA No.73 of 2022 For Appellant : Mr.T.Ravikumar Senior Standing Counsel For Respondent : Mr.R.Venkatanarayanan For M/s. Subbaraya Aiyar Padmanabhan JUDGMENT (Judgment of the Court was delivered by the Hon'ble Chief Justice) Heard learned counsel for the appellant/Revenue and learned counsel for the respondent/assessee. 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 questions 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: 28/08/2025 05:40:11 pm ) TCA No.73 of 2022 3. In that view of the matter, the appeal stands dismissed. There shall be no order as to costs. (MANINDRA MOHAN SHRIVASTAVA, CJ) (SUNDER MOHAN,J)

26.08.2025 Index : Yes/No Neutral Citation : Yes/No kpl To 1. The Assistant Registrar Income Tax Appellate Tribunal “B” Bench, Chennai. 2. The Commissioner of Income Tax, Corporate Circle 2(2) Chennai. 3. The Deputy Commissioner of Income Tax (Appeals) - 6 Chennai. ____________ Page 3 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 28/08/2025 05:40:11 pm ) TCA No.73 of 2022 THE HON'BLE CHIEF JUSTICE AND SUNDER MOHAN,J. (kpl)

TCA No.73 of 2022

26.08.2025 ____________ Page 4 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 28/08/2025 05:40:11 pm )

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