COMMISSIONER OF INCOME TAX vs. M/S.SAVORIT LTD
What did the High Court hold?
The High Court recorded the submission made by the learned Senior Standing Counsel for the appellant Revenue that both appeals were under low tax effect. Based on this submission, the Court ordered that both appeals stand dismissed. The Court explicitly stated that the questions of law raised in these appeals are kept open to be decided at the appropriate point of time. No order as to costs was made. The principle derived is that appeals can be dismissed on the ground of low tax effect, even if the questions of law are substantial, with the liberty to revisit them later.
What were the facts?
The appeals were filed by the Commissioner of Income Tax, Chennai (Revenue) against the orders of the Income Tax Appellate Tribunal, Madras 'A' Bench, dated 04.02.2015 in ITA Nos.2708/Mds/2014 and 2793/Mds/2014. The respondent in both appeals is M/s. Savorit Ltd. The appeals were filed under Section 260A of the Income Tax Act, 1961. The Revenue brought to the notice of the High Court that both appeals were under 'low tax effect'. Consequently, the High Court was requested to dispose of the appeals on this ground.
What were the issues?
1. Whether the appeals filed by the Revenue are to be dismissed on the ground of low tax effect, as contended by the Revenue itself? The Revenue contended that both appeals are under low tax effect and therefore, they could be disposed of. The judgment does not record any specific arguments from the respondent assessee, M/s. Savorit Ltd., on the merits of the case or on the issue of low tax effect.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
T.C.A.Nos.936 and 937 of 2015 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 02.09.2024 CORAM : THE HONOURABLE MR.JUSTICE R. SURESH KUMAR AND THE HONOURABLE MR.JUSTICE C. SARAVANAN T.C.A.Nos.936 and 937 of 2015 Commissioner of Income Tax Chennai.
.. Appellant in both T.C.As Vs. M/s.Savorit Ltd. New No.22, North Terminus Road Tollgate, Chennai – 600 081. .. Respondent in both T.C.As Prayer in T.C.A.No.936 of 2015: Appeal filed under Section 260A of the Income Tax Act, 1961, against the order of the Income Tax Appellate Tribunal, Madras 'A' Bench, dated 04.02.2015 in ITA No.2708/Mds/2014; and Prayer in T.C.A.No.937 of 2015: Appeal filed under Section 260A of the Income Tax Act, 1961, against the order of the Income Tax Appellate Tribunal, Madras 'A' Bench, dated 04.02.2015 in ITA No.2793/Mds/2014. For the Appellant Mr.T.Ravi Kumar in both T.C.As : Senior Standing Counsel For the Respondent in both T.C.As : Mr.G.Baskar Page 1 of 3 https://www.mhc.tn.gov.in/judis T.C.A.Nos.936 and 937 of 2015 COMMON JUDGMENT (Order of the Court was made by R.SURESH KUMAR, J.) It is brought to our notice by Mr.T.Ravi Kumar, learned Senior Standing Counsel appearing for the appellant Revenue that both these appeals are under low tax effect. Accordingly, they could be disposed. 2. Recording the same, both these appeals stand dismissed. The questions of law raised in these appeals are kept open to be decided at the appropriate point of time. There shall be no order as to costs. (R.S.K., J.) (C.S.N, J) 02.09.2024 Neutral Citation:Yes/No drm Page 2 of 3 https://www.mhc.tn.gov.in/judis T.C.A.Nos.936 and 937 of 2015 R. SURESH KUMAR, J. AND C. SARAVANAN
, J.
(drm) T.C.A.Nos.936 and 937 of 2015 02.09.2024
Page 3 of 3 https://www.mhc.tn.gov.in/judis
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