The Pr Commissioner Of Income Tax 1 vs. Dr. M. N.Kumaresan
What did the High Court hold?
The High Court noted the submission by the Revenue's counsel that the case involved a low tax effect. Citing Circular No. 05/2024 and Circular No. 09/2024, the Revenue stated its intention not to proceed with the appeal. The Court acknowledged this position. Consequently, the appeal was dismissed. The Court explicitly stated that the questions of law are kept open for consideration in an appropriate matter, implying no decision on the merits of the case. No specific findings on any issues were made by the High Court, as the dismissal was based on the Revenue's decision not to pursue the appeal.
What were the facts?
The appeal was filed by the Principal Commissioner of Income Tax - 1, Chennai (the Revenue) against an order dated 21.09.2023 passed by the Income Tax Appellate Tribunal ('B' Bench, Chennai). The respondent is Dr. M N Kumaresan (the assessee). The appeal is preferred under Section 260A of the Income Tax Act, 1961. The specific assessment year(s) and the amount in dispute are not recorded in the judgment. The procedural history leading to the Tribunal's order is not detailed.
What were the issues?
The judgment does not explicitly frame specific questions of law for determination. However, the appeal concerns the order of the Income Tax Appellate Tribunal. The Revenue, through its counsel, submitted that the case has a low tax effect. Consequently, the Revenue stated that it does not wish to proceed with the matter, citing 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 assessee's contentions are not recorded as the Revenue decided not to press the appeal. The Revenue also indicated that the questions of law may be kept open for consideration in an appropriate matter.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
TCA No.77 of 2024 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.77 of 2024 The Principal Commissioner of Income Tax - 1 Chennai. .. Appellant Vs. Dr.M N Kumaresan .. Respondent Prayer : Appeal filed under Section 260A of the Income Tax Act, 1961 against the order dated 21.09.2023 passed in ITA No.1623/CHNY/2019 on the file of Income Tax Appellate Tribunal 'B' Bench, Chennai. For Appellant : Mr.T.Ravikumar Senior Standing Counsel For Respondent : Mr.G.Tarun For Mr.A.S.Sriraman JUDGMENT (Judgment of the Court was delivered by the Hon'ble Chief Justice) Heard learned counsel for the appellant/Revenue and learned ____________ Page 1 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 28/08/2025 05:40:11 pm ) TCA No.77 of 2024 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. 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 ____________ Page 2 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 28/08/2025 05:40:11 pm ) TCA No.77 of 2024 To 1. The Assistant Registrar Income Tax Appellate Tribunal “B” Bench, Chennai. 2. The Commissioner of Income Tax (Appeals) - 2 Chennai. 3. The Income Tax Officer Non-Corporate Ward-1(4) Chennai. ____________ Page 3 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 28/08/2025 05:40:11 pm ) TCA No.77 of 2024 THE HON'BLE CHIEF JUSTICE AND SUNDER MOHAN,J. (kpl)
TCA No.77 of 2024
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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