DEPUTY COMMISSIONER OF INCOME TAX vs. R STAHL PRIVATE LIMITED

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TCA/73/2024HC Madras17 June 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 and Mr. Justice Sunder Mohan, considered the submission made by the Revenue's counsel. The counsel informed the court that the monetary limit of the appeal was below the threshold stipulated in CBDT Circular No.09/2024, and based on instructions, the appeal was to be withdrawn. The court noted that the withdrawal was specifically due to the monetary limit and not an admission on the merits of the case. Therefore, the appeal was dismissed as withdrawn. No order as to costs was made.

What were the facts?

This case involves an appeal filed by the Deputy Commissioner of Income Tax, Corporate Circle-5(2), Chennai (the Revenue) against an order of the Income Tax Appellate Tribunal (ITAT), 'D' Bench, Chennai, dated 26.08.2022 in ITA No.55/Chny/2018. The respondent is R Stahl Private Limited. The appeal was filed under Section 260A of the Income Tax Act, 1961. The monetary limit involved in this appeal was stated to be below the prescribed limit in Circular No.09/2024, dated 17.09.2024, issued by the Ministry of Finance, Department of Revenue, Central Board of Direct Taxes.

What were the issues?

1. Whether the appeal, due to its monetary value being below the prescribed limit in CBDT Circular No.09/2024, should be withdrawn by the Revenue. The Revenue, through its counsel Ms. Pushpa, stated that the monetary limit involved in the appeal is below the limit prescribed in Circular No.09/2024, dated 17.09.2024. Consequently, she had instructions to withdraw the appeal. The counsel clarified that the withdrawal was solely based on the monetary limit and did not involve conceding the Department's stand on the merits of the case. No specific arguments were recorded from the assessee's side regarding the withdrawal.

Which sections of the Income-tax Act were involved?

Section 260A

AI-generated summary — verify with the full judgment below

TCA No.73 of 2024 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 17.06.2025 CORAM : THE HON'BLE MR.K.R.SHRIRAM, CHIEF JUSTICE AND THE HON'BLE MR.JUSTICE SUNDER MOHAN TCA No.73 of 2024 The Deputy Commissioner of Income Tax Corporate Circle-5(2), Main Building, 4th Floor, M.G.Road, Nungambakkam, Chennai - 600 034. Appellant Vs R Stahl Private Limited Plot No.5, Malrosapuram Main Road, Sengundram Koil, Malrosapuram, Post, Kancheepuram District-603 204. Respondent Prayer: Appeal filed under Section 260A of the Income Tax Act, 1961 against the order of the Income Tax Appellate Tribunal “D” Bench, Chennai, dated 26.08.2022 in ITA No.55/Chny/2018. For Appellant: Ms.V.Pushpa __________ Page 1 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 18/06/2025 04:22:55 pm ) TCA No.73 of 2024 For Respondent: Mr.R.Venkatanarayanan for M/s. Subbaraya Aiyar Padmanaban JUDGMENT (Delivered by the Hon'ble Chief Justice) Ms.Pushpa states that the monetary limit involved in this appeal is below the monetary limit prescribed in 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 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. Appeal stands dismissed as withdrawn. There shall be no order as to costs. (K.R.SHRIRAM, CJ.) (SUNDER MOHAN, J.)

17.06.2025 Index : Yes/No Neutral Citation : Yes/No __________ Page 2 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 18/06/2025 04:22:55 pm ) TCA No.73 of 2024 sasi To: 1. The Assistant Registrar Income Tax Appellate Tribunal Chennai. 2. The Assistant Commissioner of Income Tax, Corporate Circle-5(2), Chennai. __________ Page 3 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 18/06/2025 04:22:55 pm ) TCA No.73 of 2024 THE HON'BLE CHIEF JUSTICE AND SUNDER MOHAN,J. (sasi)

TCA No.73 of 2024

17.06.2025 __________ Page 4 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 18/06/2025 04:22:55 pm )

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