THE PRINCIPAL COMMISSIONER OF INCOME TAX vs. M/S.FOUR M MARITIME PVT., LTD.,

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TCA/89/2021HC Madras16 December 2025Bench: Honourable The CHIEF JUSTICE3 pages
AI SummaryDismissed

What did the High Court hold?

The High Court, in view of the submission made by the learned counsel for the Revenue, decided to dismiss the appeal. The Revenue, acknowledging the low tax effect of the case, stated its intention not to proceed further, citing relevant circulars from the CBDT. The Court accepted this submission and disposed of the appeal accordingly. The Revenue's counsel explicitly mentioned that the question of law may be kept open for consideration in an appropriate future matter, indicating that no decision on the merits of the case was made. The operative direction was that the appeal stands dismissed, with no order as to costs.

What were the facts?

The appeal was filed by the Principal Commissioner of Income Tax, Corporate Ward 2(2), Chennai (Revenue) against an order of the Income Tax Appellate Tribunal, Madras C Bench, dated 31.07.2018 in ITA No.207/Chny/2018. The respondent is M/s. Four M Maritime Pvt. Ltd. The appeal was filed under Section 260A of the Income Tax Act, 1961. The Revenue, at the outset, submitted that the case had a low tax effect. Consequently, the Revenue did not wish to proceed with the matter, citing Circular No. 05/2024 and Circular No. 09/2024.

What were the issues?

1. Whether the appeal should be dismissed on the grounds of low tax effect as per the CBDT circulars. (Question of law) The Revenue, through its counsel, submitted that the case has a low tax effect. 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 appellant/Revenue does not wish to proceed with the matter. The Revenue also stated that the question of law may be kept open for consideration in an appropriate matter. The judgment does not record any specific arguments from the respondent.

Which sections of the Income-tax Act were involved?

Section 260A

AI-generated summary — verify with the full judgment below

T.C.A.No.89 of 2021 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 16.12.2025 CORAM : THE HONOURABLE MR. MANINDRA MOHAN SHRIVASTAVA, CHIEF JUSTICE AND THE HONOURABLE MR.JUSTICE G.ARUL MURUGAN T.C.A.No.89 of 2021 The Principal Commissioner Of Income Tax Corporate Ward 2(2) Chennai 34. Appellant(s) Vs M/s.Four M Maritime Pvt., Ltd. No.4, Buhari Towers, Moores Road Egmore Chennai 31. PAN AAACF6163E Respondent(s) Prayer : Appeal filed under Section 260A of the Income Tax Act, 1961, against the order of the Income Tax Appellate Tribunal, Madras C Bench dated 31.07.2018 in ITA No.207/Chny/2018. For Appellant(s): Mr.T.Ravi Kumar Senior Standing Counsel For Respondent(s): Mr.G.Baskar __________ Page 1 of 3 https://www.mhc.tn.gov.in/judis ( Uploaded on: 17/12/2025 03:53:17 pm ) T.C.A.No.89 of 2021 JUDGMENT (Judgment of the Court was delivered by the Hon'ble Chief Justice) Heard learned counsel for the appellant/Revenue and learned counsel for the respondent. 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)

16.12.2025 kpl __________ Page 2 of 3 https://www.mhc.tn.gov.in/judis ( Uploaded on: 17/12/2025 03:53:17 pm ) T.C.A.No.89 of 2021 THE HON'BLE CHIEF JUSTICE AND G.ARUL MURUGAN,J. (kpl) T.C.A.No.89 of 2021

16.12.2025 __________ Page 3 of 3 https://www.mhc.tn.gov.in/judis ( Uploaded on: 17/12/2025 03:53:17 pm )

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