PRINCIPAL COMMISSIONER OF INCOME TAX vs. Patchirajan Lakshmanan

TCA/90/2026HC Madras04 August 2026Bench: Honourable The CHIEF JUSTICE4 pages

AI SummaryWithdrawn

What did the High Court hold?

The High Court disposed of the tax case appeal on the ground that the monetary limit involved was below the limit prescribed in Circular No.09/2024 dated 17.09.2024. Consequently, the appeal was disposed of without deciding the substantial questions of law raised therein. The Court explicitly stated that the substantial questions of law are left open to be considered in an appropriate case. There was no order as to costs. The operative direction was to dispose of the appeal, leaving the substantial questions of law undecided.

What were the facts?

The Revenue, represented by the Principal Commissioner of Income Tax, Central Circle, filed an appeal before the High Court of Judicature at Madras against an order dated 28.06.2024 passed by the Income Tax Appellate Tribunal (ITAT), "B" Bench, Chennai, in ITA No.597/Chny/2020. The assessee is Patchirajan Lakshmanan. The appeal was filed under Section 260A of the Income Tax Act, 1961. The High Court noted that the monetary limit involved in the appeal was below the prescribed limit in Circular No.09/2024 dated 17.09.2024, issued by the Ministry of Finance, Department of Revenue, Central Board of Direct Taxes.

What were the issues?

1. Whether the appeal filed by the revenue is maintainable before the High Court given that the monetary limit involved is below the threshold prescribed by CBDT Circular No.09/2024? The Revenue contended that the appeal was filed against an order of the ITAT. The judgment does not record any specific arguments from the Revenue regarding the substantial questions of law. The Respondent (assessee) did not present any arguments as the appeal was disposed of on the preliminary ground of monetary limit. The judgment does not explicitly state the substantial questions of law that were raised by the Revenue, other than implying that such questions existed.

Which sections of the Income-tax Act were involved?

Section 260A

AI-generated summary — verify with the full judgment below

T.C.A.No.90 of 2026 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 04.08.2026 CORAM : THE HONOURABLE MR. SUSHRUT ARVIND DHARMADHIKARI, CHIEF JUSTICE AND THE HONOURABLE MR.JUSTICE G.ARUL MURUGAN T.C.A.No.90 of 2026 The Principal Commissioner of Income Tax Central Circle. Appellant Vs Patchirajan Lakshmanan No.102F/16Z/3 Dhanasekaran Nagar Polepettai (West) – 628 002 PAN: AAZPL 1396H Respondent PRAYER

: Appeal filed under Section 260A of the Income Tax Act, 1961 against the order of the Income Tax Appellate Tribunal “B” Bench, Chennai, dated 28.06.2024 in ITA No.597/Chny/2020. For Appellant: Mr.D.Prabu Mukunth Arunkumar Sr. Standing Counsel For Respondent: Mr.A.S.Sriraman ______________ Page 1 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 05/08/2026 12:38:26 pm ) T.C.A.No.90 of 2026 JUDGMENT (Delivered by the Hon'ble Chief Justice) This appeal has been filed by the revenue against the order dated 28.06.2024 passed by the Income Tax Appellate Tribunal “B” Bench, Chennai in I.T.A.No.597/Chny/2020. 2. The monetary limit involved in this appeal is below the monetary limit prescribed in 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. Therefore, the tax case appeal stands disposed of. There shall be no order as to costs. We make it clear that the substantial questions of law raised in this appeal are left open to be considered in an appropriate case. (SUSHRUT ARVIND DHARMADHIKARI, CJ) (G.ARUL MURUGAN,J)

04.08.2026 Index : Yes/No Neutral Citation : Yes/No bbr ______________ Page 2 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 05/08/2026 12:38:26 pm ) T.C.A.No.90 of 2026 To: 1. The Assistant Registrar Income Tax Appellate Tribunal Chennai Benches, Chennai. 2. The Principal Commissioner of Income Tax-1 Madurai. 3. The Income Tax Officer, O/o. the Joint Commissioner of Income Tax, Central Range, Madurai. ______________ Page 3 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 05/08/2026 12:38:26 pm ) T.C.A.No.90 of 2026 THE HON'BLE CHIEF JUSTICE AND G.ARUL MURUGAN,

bbr T.C.A.No.90 of 2026

04.08.2026 ______________ Page 4 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 05/08/2026 12:38:26 pm )

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