COMMISSIONER OF INCOME TAX vs. THE KARUR VYSYA BANK

PDF · subscribers
TCA/808/2019HC Madras12 September 2025Bench: Honourable The CHIEF JUSTICE4 pages
AI SummaryDismissed

What did the High Court hold?

The High Court, upon hearing the learned counsel for both the appellant (Revenue) and the respondent (Assessee), noted the submission by the Revenue 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 stated they did not wish to proceed with the appeal. The Court acknowledged this and decided to keep the question of law open for consideration in an appropriate matter. Consequently, the appeal was dismissed without any order as to costs. The specific findings of the ITAT or the underlying substantive issues of the appeal were not discussed or decided by the High Court.

What were the facts?

This case involves an appeal filed by the Commissioner of Income Tax (Revenue) against an order of the Income Tax Appellate Tribunal (ITAT), Madras "B" Bench, dated 28.02.2019. The assessee is The Karur Vysya Bank. The appeal is filed under Section 260A of the Income-tax Act, 1961. The specific assessment year(s) and the amount in dispute are not explicitly stated in the provided text. The procedural history is limited to the filing of the appeal by the Revenue against the ITAT's order.

What were the issues?

1. Whether the appeal filed by the Revenue should be dismissed on the grounds of low tax effect, as per CBDT Circulars No. 05/2024 and 09/2024? (Question of law). The Revenue argued that due to the low tax effect, they do not wish to proceed with the matter, while reserving the right to have the question of law considered in an appropriate future case. The Assessee's arguments 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

T.C.A.No.808 of 2019 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 12.09.2025 CORAM : THE HONOURABLE MR. MANINDRA MOHAN SHRIVASTAVA, CHIEF JUSTICE AND THE HONOURABLE MR.JUSTICE G.ARUL MURUGAN T.C.A.No.808 of 2019 The Commissioner of Income Tax Circle I(1) Thiruchirapalli Appellant Vs The Karur Vysya Bank Erode Road Karur-639 002 Respondent PRAYER

: Appeal filed under Section 260A of the Income-tax Act, 1961 against the order of the Income Tax Appellate Tribunal, Madras “B” Bench, dated 28.02.2019 in ITA No.1344/Chny/2013. For Appellant: M/s.V.Mahalingam P.E.R.Mangala Suvigaran Standing Counsel For Respondent: Mr.R.Venkatanarayanan for M/s.Subbaraya Aiyar Padmanabhan & Ramamani ______________ Page 1 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 16/09/2025 04:41:11 pm ) T.C.A.No.808 of 2019 JUDGMENT (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 question 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) (G.ARUL MURUGAN,J)

12.09.2025 Index : Yes/No Neutral Citation : Yes/No bbr ______________ Page 2 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 16/09/2025 04:41:11 pm ) T.C.A.No.808 of 2019 To: 1. The Assistant Registrar Income Tax Appellate Tribunal “B” Bench, Chennai. 2. The Commissioner of Income Tax (Appeals), Tiruchirappalli. 3. The Assistant Commissioner of Income Tax, Company Circle-I, Range-I, Tiruchirapalli. ______________ Page 3 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 16/09/2025 04:41:11 pm ) T.C.A.No.808 of 2019 THE HON'BLE CHIEF JUSTICE AND G.ARUL MURUGAN,J. bbr

T.C.A.No.808 of 2019

12.09.2025 ______________ Page 4 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 16/09/2025 04:41:11 pm )

Recent GST High Court judgments

Search GST case law →