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Principal Commissioner Of Income Tax - 3Chennai v. M/S.sicagen India Ltd.4Th Floor Spic House88 Mount Road, Guindychennai 600 032Pan: Aakcs5770J

High Court 18 Nov 2024 In favour of: Assessee

Forum / Bench

High Court · hc_cis_mas

Parties

Date of order

18 Nov 2024

Assessment year(s)

—

Outcome

Dismissed

Case summary

In Principal Commissioner Of Income Tax - 3Chennai v. M/S.sicagen India Ltd.4Th Floor Spic House88 Mount Road, Guindychennai 600 032Pan: Aakcs5770J, the High Court (2024) dismissed the appeal under Section 260A, Section 115JB of the Income-tax Act. The decision went in favour of the assessee.

Issue: For the Appellant:Mr.J.NarayanasamySenior Standing Counsel [SECTION] ## JUDGMENT (Order of the Court was made by R.SURESH KUMAR, J.) The substantial questions of law raised in the present tax case appeal are:- (i) Whether on the facts and in the circumstances of the case and in law, the Tribunal was right in holding th...

Decision: Recording the same, the present appeal stands dismissed as Low Tax Effect.

Summary auto-generated from the order below — read the full judgment for the complete reasoning.

Sections referenced in this judgment

Section 260A case law →Section 115JB case law →

The order — as passed by the High Court

IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 18.11.2024 CORAM : THE HONOURABLE MR.JUSTICE R. SURESH KUMARAND THE HONOURABLE MR.JUSTICE C. SARAVANAN T.C.A.No.261 of 2024 Principal Commissioner of Income Tax - 3Chennai...Appellant Vs. M/s.Sicagen India Ltd.4th Floor SPIC House88 Mount Road, GuindyChennai 600 032PAN: AAKCS5770J..Respondent Prayer: Appeal filed under Section 260A of the Income Tax Act, 1961, against the order of the Income Tax Appellate Tribunal "C" Bench, Chennai, dated 17.10.2022 in I.T.A.No.271/Chny/2022. For the Appellant:Mr.J.NarayanasamySenior Standing Counsel JUDGMENT (Order of the Court was made by R.SURESH KUMAR, J.) The substantial questions of law raised in the present tax case appeal are:- (i) Whether on the facts and in the circumstances of the case and in law, the Tribunal was right in holding that disallowance u/s. 14A shall not form part of the book profit under Section 115JB of the Act and quashed the order passed u/s.263? (ii) Whether on the facts and in the circumstances of the case and in law, the Tribunal was right in holding that the disallowance u/s.14A shall not form part of the book profit u/s.115JB when clause (f) of explanation 1 to Section 115JB warrants additions of such expenditure relatable to exempt income? 2. It is submitted by Mr.J.Narayanasamy, learned Senior Standing Counsel appearing for the appellant Revenue that the present Tax Case Appeal is covered under the Low Tax Effect as per the recent Circular dated 17.09.2024, in Circular No.9/2024. 3. Recording the same, the present appeal stands dismissed as Low Tax Effect. The questions of law raised in this appeal are kept open to be decided at the later point of time. There shall be no order as to costs. (R.S.K., J.) (C.S.N, J) 18.11.2024 Neutral Citation:Yes/No drm https://www.mhc.tn.gov.in/judis T.C.A.No.261 of 2024 R. SURESH KUMAR, J.ANDC. SARAVANAN, J.(drm) T.C.A.No.261 of 2024 18.11.2024

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