Commissioner Of Income Taxappellantcentral Circle – 1, Coimbatore...in Both T.c.as v. Senthil Papain & Food Products Pvt. Ltd.107-A, Sengupta Roadramnagar, Coimbatore 641 009Respondentpan: Aaccs 7187 B..in Both T.c.as

IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 15.10.2024 CORAM : THE HONOURABLE MR.JUSTICE R. SURESH KUMARAND THE HONOURABLE MR.JUSTICE C. SARAVANAN T.C.A.Nos.65 & 66 of 2023 Commissioner of Income TaxAppellantCentral Circle – 1, Coimbatore...in both T.C.As Vs. Senthil Papain & Food Products Pvt. Ltd.107-A, Sengupta RoadRamnagar, Coimbatore 641 009RespondentPAN: AACCS 7187 B..in both T.C.As Prayer in T.C.A.No.65 of 2023: Appeal filed under Section 260-A of the Income Tax Act, 1961, against the order of Income Tax Appellate Tribunal, “B” Bench, Chennai dated 28.09.2022 passed in I.T.A.No.467/CHNY/2012; and Prayer in T.C.A.No.66 of 2023: Appeal filed under Section 260-A of the Income Tax Act, 1961, against the order of Income Tax Appellate Tribunal, “B” Bench, Chennai dated 28.09.2022 passed in I.T.A.No.465/CHNY/2012. For the Appellantin both T.C.As :Mr.Karthik RanganathanSenior Standing Counsel For the Respondentin both T.C.As:Mr.A.S.Sriraman COMMON JUDGMENT (Order of the Court was made by R.SURESH KUMAR, J.)These tax case appeals were admitted on 15.02.2023 by this Court on the following substantial question of law:- "1. Whether on the facts and circumstances of the case the ITAT was right in deleting the additions made under Section 40(A)(2) without considering that the assessee has not produced any contemporaneous evidence or materials to prove that the payment made are reasonable and exclusively for the purpose of business?" 2. It is submitted by the learned Senior Standing Counsel appearing for the appellant Revenue that these matters are covered under the Low Tax Effect as per the recent Circular dated 17.09.2024, in Circular No.9/2024. 3. Hence, these appeals stand dismissed, as covered under the low tax effect and the substantial question of law arising in these appeals is kept open to be decided at the later point of time. There shall be no order as to costs. Neutral Citation:Yes/Nodrm (R.S.K., J.) (C.S.N, J) 15.10.2024 https://www.mhc.tn.gov.in/judis T.C.A.Nos.65 & 66 of 2023 R. SURESH KUMAR, J.ANDC. SARAVANAN, J. (drm) T.C.A.Nos.65 & 66 of 2023 15.10.2024