THE COMMISSIONER OF INCOME TAX vs. M/S. THE TAMIL NADU STATE TRANSPORT

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TCA/831/2019HC Madras22 September 2025Bench: Honourable The CHIEF JUSTICE4 pages
AI SummaryDismissed

What did the High Court hold?

The High Court, after hearing the learned counsel for the Revenue, noted the submission that the case has a low tax effect. In view of the Circulars No. 05/2024 and 09/2024 issued by the CBDT, the Revenue stated that it did not wish to proceed with the appeal. Consequently, the High Court dismissed the appeal. The court explicitly mentioned that the question of law may be kept open for consideration in an appropriate matter. No specific finding was made on the merits of the case, and the operative direction was the dismissal of the appeal. No issue was left undecided, as the appeal was disposed of on the Revenue's submission regarding low tax effect.

What were the facts?

The Revenue, Commissioner of Income Tax, Trichy, filed an appeal under Section 260A of the Income Tax Act, 1961, against an order dated January 30, 2015, passed by the Income Tax Appellate Tribunal (ITAT), Madras 'B' Bench, Chennai. The appeal pertains to Assessment Year 2007-08 and concerns M/s. The Tamil Nadu State Transport Corporation (Kumbakonam) Ltd. as the assessee. The procedural history involves the ITAT's order being challenged by the Revenue before the High Court. The amount in dispute is not explicitly stated but is implied to be of low tax effect.

What were the issues?

1. Whether the appeal filed by the Revenue should be dismissed due to low tax effect, as per CBDT Circulars? (Question of law) The Revenue argued that while a question of law may exist, they do not wish to proceed with the matter due to its low tax effect. They 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. 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

TCA No.831 of 2019 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 22.09.2025 CORAM THE HON'BLE MR.MANINDRA MOHAN SHRIVASTAVA, CHIEF JUSTICE AND THE HON'BLE MR.JUSTICE G.ARUL MURUGAN TCA No.831 of 2019 Commissioner of Income Tax Trichy. .. Appellant -vs- M/s.The Tamil Nadu State Transport Corporation (Kumbakonam) Ltd., No.27 Railway Station New Road, Kumbakonam 612 001. (PAN: AAACC1294K) .. Respondent Prayer: Appeal filed under Section 260A of the Income Tax Act, 1961, against the order dated 30.01.2015 passed in ITA No.812/Mds/2014 on the file of the Income Tax Appellate Tribunal, Madras “B” Bench, Chennai, for the Assessment Year 2007-08. For Appellant : Mr.V.Mahalingam Senior Standing Counsel and Mr.P.E.R.Mangala Suvigaran, Junior Standing Counsel For Respondent : Mr.G.Tarun for Mr.A.S.Sriraman * * * * * Page 1 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 23/09/2025 04:39:40 pm ) TCA No.831 of 2019 JUDGMENT (Delivered by the Hon'ble Chief Justice) Heard learned counsel for the appellant/Revenue. Mr.G.Tarun, learned counsel, 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.) (G.ARUL MURUGAN, J.) 22.09.2025 Index : Yes/No Neutral Citation : Yes/No sra Page 2 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 23/09/2025 04:39:40 pm ) TCA No.831 of 2019 To 1. The Income Tax Appellate Tribunal, Madras 'B' Bench, Chennai. 2. The Commissioner of Income Tax, Trichy. Page 3 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 23/09/2025 04:39:40 pm ) TCA No.831 of 2019 THE HON'BLE CHIEF JUSTICE AND G.ARUL MURUGAN

, J.

(sra) TCA No.831 of 2019 22.09.2025 Page 4 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 23/09/2025 04:39:40 pm )

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