Commissioner Of Income Taxinternational Taxation, Chennai - 600 034 v. Eos Gmbh India Branch Officeno
High Court
11 Sep 2025 In favour of: Assessee
Forum / Bench
High Court · hc_cis_mas
Parties
Commissioner Of Income Taxinternational Taxation, Chennai - 600 034 v. Eos Gmbh India Branch Officeno
Date of order
11 Sep 2025
Assessment year(s)
—
Outcome
Dismissed
Case summary
In Commissioner Of Income Taxinternational Taxation, Chennai - 600 034 v. Eos Gmbh India Branch Officeno, the High Court (2025) dismissed the appeal. The decision went in favour of the assessee.
Decision: 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...
Summary auto-generated from the order below — read the full judgment for the complete reasoning.
Sections referenced in this judgment
The order — as passed by the High Court
IN THE HIGH COURT OF JUDICATURE AT MADRAS
DATED: 11.09.2025
CORAM :
THE HONOURABLE MR. MANINDRA MOHAN SHRIVASTAVA, CHIEF JUSTICEAND
THE HONOURABLE MR.JUSTICE G.ARUL MURUGAN
T.C.A.No.59 of 2025and C.M.P.No.6937 of 2025
Commissioner of Income TaxInternational Taxation, Chennai - 600 034.
Appellant
Vs
EOS GmbH India Branch OfficeNo. 36, Ground Floor, Sivananda Nagar, Kolathur, Chennai – 600 009.
Respondent
PRAYER: Appeal filed under Section 260A of the Income-tax Act, 1961 against the order of the Income Tax Appellate Tribunal, Madras “D” Bench, dated 22.12.2023 in IT (TP) A No.16/Chny/2021.
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Page 1 of 4
For Appellant:
Mr.Dineshfor Mr.Karthik Ranganathan[Through VC]
JUDGMENT
(Delivered by the Hon'ble Chief Justice)
Heard Mr.Dinesh, learned counsel for the appellant/Revenue, who is appearing through video-conferencing.
2. Mr.Dinesh, learned counsel for the appellant, on
instructions from Mr.Karthik Ranganathan, learned Senior Standing Counsel, 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.
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Page 2 of 4
T.C.A.No.59 of 2025
In that view of the matter, the appeal stands dismissed.
There shall be no order as to costs. Consequently, interim application stands closed.
(MANINDRA MOHAN SHRIVASTAVA, CJ) (G.ARUL MURUGAN,J) 11.09.2025
Index: Yes/NoNeutral Citation:Yes/Nosasi
To:
1. The Assistant Registrar
Income Tax Appellate Tribunal
Chennai Benches, Chennai.
2. The Joint Commissioner of Income Tax (HQ)
and Secretary, Dispute Resolution Panel-2 A Wing, 4[th] Floor, Kendriya Sadan A Wing, 4[th] Floor, Kendriya Sadan
Koramangala, Bengaluru – 560 034.
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Page 3 of 4
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Page 4 of 4
T.C.A.No.59 of 2025
THE HON'BLE CHIEF JUSTICE ANDG.ARUL MURUGAN,J.
(sasi)
T.C.A.No.59 of 2025
11.09.2025
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