COMMISSIONER OF INCOME TAX vs. M/S TRACTORS & FARM EQUIPMENTS

TCA/730/2017HC Madras04 August 2025Bench: Honourable The CHIEF JUSTICE4 pages

AI SummaryDismissed

What did the High Court hold?

The High Court, considering the submissions made by the learned counsel for the Revenue, noted that the Revenue itself submitted that the case has 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 Ministry of Finance, Department of Revenue, Central Board of Direct Taxes, the Revenue expressed its unwillingness to proceed with the appeal. The Court accepted this submission and accordingly dismissed the appeal. The question of law was expressly kept open for consideration in an appropriate matter. No order as to costs was made.

What were the facts?

The appeal was filed by the Commissioner of Income Tax, Corporate Circle-3, Chennai (appellant/Revenue) against the order dated 02.11.2016 passed by the Income Tax Appellate Tribunal, Madras “D” Bench, Chennai. The assessee is M/s. Tractors and Farm Equipments Limited. The assessment year in question is 2011-12. The appeal was filed under Section 260A of the Income Tax Act, 1961. The Revenue, through its counsel, submitted that the case has a low tax effect. Consequently, 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 did not wish to proceed with the matter.

What were the issues?

1. Whether the appeal filed by the Revenue should be dismissed on the grounds of low tax effect, as per the CBDT circulars? (Question of law and fact, relying on Circular No.05/2024 and Circular No.09/2024). Assessee's Contention: The assessee is not recorded as having made any specific arguments in the judgment. The appeal was dismissed based on the Revenue's submission. Revenue's Contention: The Revenue, through its counsel, fairly submitted that the case has a low tax effect. Therefore, in view of Circular No.05/2024 dated 15.03.2024 and Circular No.09/2024, dated 17.09.2024, the appellant/Revenue does not wish to proceed with the matter, though the question of law may be kept open for consideration in an appropriate matter.

Which sections of the Income-tax Act were involved?

Section 260A

AI-generated summary — verify with the full judgment below

TCA No.730 of 2017 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 04.08.2025 CORAM THE HON'BLE MR.MANINDRA MOHAN SHRIVASTAVA, CHIEF JUSTICE AND THE HON'BLE MR.JUSTICE SUNDER MOHAN TCA No.730 of 2017 Commissioner of Income Tax, Corporate Circle-3, Chennai. .. Appellant -vs- M/s.Tractors and Farm Equipments Limited, No.35, Pottipatti Plaza, Nungambakkam High Road, Chennai 600 034 PAN: AACT2761Q .. Respondent Prayer: Appeal filed under Section 260A of the Income Tax Act, 1961, against the order dated 02.11.2016 passed in ITA No.2106/Mds/2016 on the file of the Income Tax Appellate Tribunal, Madras “D” Bench, Chennai, for the Assessment Year 2011-12. For Appellant : Mr.J.Narayanaswamy Senior Stdg. Counsel For Respondent : Mr.R.Vijayaraghavan for M/s.Subbaraya Aiyar Padmanabhan Page 1 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 07/08/2025 04:17:37 pm ) TCA No.730 of 2017 JUDGMENT (Delivered by the Hon'ble Chief Justice) Heard learned counsel for the appellant/Revenue. Mr.Vijayaraghavan appears 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 question of law may be kept open for consideration in the appropriate matter. 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.) 04.08.2025 Index : Yes/No Neutral Citation : Yes/No sra Page 2 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 07/08/2025 04:17:37 pm ) TCA No.730 of 2017 To 1. The Income Tax Appellate Tribunal, Madras 'D' Bench, Chennai. 2. The Commissioner of Income Tax, Corporate Circle-3, Chennai. Page 3 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 07/08/2025 04:17:37 pm ) TCA No.730 of 2017 THE HON'BLE CHIEF JUSTICE AND SUNDER MOHAN

, J.

(sra) TCA No.730 of 2017 04.08.2025 Page 4 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 07/08/2025 04:17:37 pm )

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