Commissioner Of Income Tax vs. M/s.Sutherland Global Services Inc.,

TCA/92/2025HC Madras12 June 2025Bench: Honourable The CHIEF JUSTICE4 pages

AI SummaryDismissed

What did the High Court hold?

The High Court dismissed the appeals filed by the Revenue. The Court found that the ITAT had set aside the assessment orders because the directions issued by the Dispute Resolution Panel (DRP) were invalid due to the absence of a Document Identification Number (DIN). The High Court observed that the facts in these appeals were similar to those in previous appeals (T.C.A.Nos.80, 81 and 82 of 2025) which it had decided on 10.06.2025. In that prior judgment, the Court had confirmed the ITAT's decision to set aside the assessment orders on the DIN issue. Therefore, the High Court held that the reasons assigned for dismissing the earlier appeals would be applicable to the instant appeals. The operative direction was the dismissal of the appeals. No issue was expressly left undecided.

What were the facts?

These appeals by the Revenue challenge common orders of the Income Tax Appellate Tribunal (ITAT), dated 22.12.2023. TCA No.92 of 2025 pertains to assessment year 2017-18 and involves assessee Sutherland Global Services Inc. TCA No.94 of 2025 relates to assessment year 2006-07 and involves assessee M/s.Watanmal Boolchand Company Ltd. The High Court notes that these appeals impugn orders that were set aside by the Court in a previous judgment concerning another assessee, dated 10.06.2025 in T.C.A.Nos.80, 81 and 82 of 2025. The procedural history indicates that the ITAT had set aside assessment orders due to invalid directions from the Dispute Resolution Panel (DRP) for want of a Document Identification Number (DIN).

What were the issues?

1. Whether the ITAT erred in setting aside the assessment orders on the ground that the directions of the Dispute Resolution Panel (DRP) were invalid for want of a Document Identification Number (DIN)? (Question of law) Assessee's Contention: The judgment does not record any specific contentions made by the assessees. The High Court's decision is based on its prior ruling. Revenue's Contention: The Revenue, represented by Mr. Karthik Ranganathan, submitted that the impugned common order dated 22.12.2023 was set aside by this Court in respect of another assessee in T.C.A.Nos.80, 81 and 82 of 2025 by an order dated 10.06.2025. The Revenue implicitly argues that the same reasoning should apply to the present appeals.

Which sections of the Income-tax Act were involved?

Section 260A

AI-generated summary — verify with the full judgment below

T.C.A.Nos.92 and 94 of 2025 IN THE HIGH COURT OF JUDICATURE AT MADRAS

DATED : 12.06.2025 CORAM THE HONOURABLE MR.K.R.SHRIRAM, CHIEF JUSTICE AND THE HONOURABLE MR.JUSTICE SUNDER MOHAN T.C.A.Nos.92 and 94 of 2025 and CMP Nos.13239, 13240, 13243 and 13244 of 2025 TCA No.92 of 2025 Commissioner of Income Tax, International Taxation Circle 2(2), Chennai – 600 034. … Appellant Vs Sutherland Global Services Inc., C/o. Dhruva Advisors LLP, Prestige Terraces, 2nd Floor, Union Street, Infantry Road, Bengaluru - 001. (PAN: AAOCS 1555P) … Respondent Prayer: Appeal filed under Section 260A of the Income Tax Act, 1961 against the common order of Income Tax Appellate Tribunal, “D” Bench, Chennai, dated 22.12.2023 passed in IT (TP) A.No.31/CHNY/2023, for the assessment years i.e., 2017-18. TCA No.94 of 2025 Commissioner of Income Tax, International Taxation, Chennai – 600 034. … Appellant __________ Page 1 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 18/06/2025 01:14:54 pm ) T.C.A.Nos.92 and 94 of 2025 Vs M/s.Watanmal Boolchand Company Ltd., C/o.CRBS and Associates LLP, Chartered Accountants, No.37, 2nd Street, Alagiri Nagar, Vadapalani, Chennai - 600 026. (PAN: AABCW 3559Q) … Respondent Prayer: Appeal filed under Section 260A of the Income Tax Act, 1961 against the common order of Income Tax Appellate Tribunal, “D” Bench, Chennai, dated 22.12.2023 passed in IT (TP) A.No.28/CHNY/2022, for the assessment years i.e., 2006-07. For Appellant : Mr.Karthik Ranganathan in both cases Sr. Standing Counsel For Respondent : Mr.N.V.Balaji in both cases COMMON JUDGMENT (Delivered by SUNDER MOHAN, J)

Mr.Karthik Ranganathan, the learned counsel for the appellant/revenue, submitted that the above two appeals impugn a common order dated 22.12.2023 that was set aside by this Court in respect of another assessee in T.C.A.Nos.80, 81 and 82 of 2025 by an order dated 10.06.2025. __________ Page 2 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 18/06/2025 01:14:54 pm ) T.C.A.Nos.92 and 94 of 2025 2. We find that in the above appeals, the orders were confirmed by this Court since the ITAT had set aside the assessment orders as the directions of the DRP were invalid for want of a DIN number. The facts are similar in this case and the reasons assigned by us for dismissal of the aforesaid appeals would be applicable to the instant appeals also. 3. Accordingly, the instant appeals are dismissed for the reasons stated in our judgment dated 10.06.2025 made in TCA Nos.80, 81 and 82 of 2025. Since we have already imposed costs in the other appeals, we refrain from imposing costs in these appeals. Consequently, interim applications stand closed. (K.R.SHRIRAM, C.J.) (SUNDER MOHAN, J.) 12.06.2025 Index: Yes/No Neutral Citation : Yes/No ars __________ Page 3 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 18/06/2025 01:14:54 pm ) T.C.A.Nos.92 and 94 of 2025 THE HON'BLE CHIEF JUSTICE AND SUNDER MOHAN, J. ars To 1. The Income Tax Appellate Tribunal, “D” Bench, Chennai. 2. The Assistant Commissioner of Income Tax (HQ) & Secretary, Dispute Resolution Panel-2, Bengaluru. 3. The Assistant Commissioner of Income Tax, International Taxation Circle 2(2), Chennai. T.C.A.Nos.92 and 94 of 2025 12.06.2025 __________ Page 4 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 18/06/2025 01:14:54 pm )

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