The Prl. Commissioner Of Income Tax-1,Chennai v. Basf Catalysts India Pvt. Limited,P8/1, Mahindra World City, Paranur,Kanchipuram-603 002

TCA Nos.100 to 106 of 2024 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 01.07.2025 CORAM : THE HON'BLE MR.K.R.SHRIRAM, CHIEF JUSTICE AND THE HON'BLE MR.JUSTICE SUNDER MOHAN TCA Nos.100 to 106 of 2024 and C.M.P.Nos.12681, 12685, 12689, 12700, 12699, 12703 and 12706 of 2024 T.C.A.No.100 of 2024: The Prl. Commissioner of Income tax-1,Chennai. Appellant Vs BASF Catalysts India Pvt. Limited,P8/1, Mahindra World City, Paranur,Kanchipuram-603 002 Respondent Prayer: Appeal filed under Section 260A of the Income Tax Act, 1961 against the order of the Income Tax Appellate Tribunal “D” Bench, Chennai, dated 22.12.2023 in IT (TP) No.1/Chny/2023. __________ Page 1 of 8 TCA Nos.100 to 106 of 2024 T.C.A.No.101 of 2024: The Prl. Commissioner of Income tax-1,Chennai. Appellant Vs GU Oceans Pvt. Ltd.,3/381, 4[th] Floor,AKDR Tower, Rajiv Gandhi Salai (OMR)Mettukuppam,Chennai-600 097 Respondent Prayer: Appeal filed under Section 260A of the Income Tax Act, 1961 against the order of the Income Tax Appellate Tribunal “D” Bench, Chennai, dated 22.12.2023 in IT (TP) No.24/Chny/2023. T.C.A.No.102 of 2024: The Prl. Commissioner of Income tax-1,Chennai. Appellant Vs Groupon Shared Services Pvt. Ltd.,Gopalan Global Axis SEZ Block, ABC G __________Page 2 of 8 TCA Nos.100 to 106 of 2024 Opposite Satya Sai Baba HospitalPlot No.152, EPIP Zone, Whitefield,Bangalore, Karnataka-560 056 Respondent Prayer: Appeal filed under Section 260A of the Income Tax Act, 1961 against the order of the Income Tax Appellate Tribunal “D” Bench, Chennai, dated 22.12.2023 in IT (TP) No.67/Chny/2022. T.C.A.No.103 of 2024: The Prl. Commissioner of Income tax-1,Chennai. Appellant Vs BGR Boilers Pvt. Ltd.,443, Guna Building,Anna Salai, 6[th] FloorTeynampet, Chennai-600 018. Respondent Prayer: Appeal filed under Section 260A of the Income Tax Act, 1961 against the order of the Income Tax Appellate Tribunal “D” Bench, Chennai, dated 22.12.2023 in IT (TP) No.68/Chny/2022. T.C.A.No.104 of 2024: The Prl. Commissioner of Income tax-1,Chennai. __________Page 3 of 8 Vs TCA Nos.100 to 106 of 2024 Appellant BNY Mellon Technology Pvt. Ltd.,(formerly known as Inautix TechnologiesIndia P Ltd.,Ground to Sixth Floor of Coral Block,3, Survey No.181/183, No.158, Old No.153Embassy Splendid Techzone,Embassy Property Development P Ltd.,SNP Infrastructure, SEZ,200 ft. Pallavaram,Thoraipakkam Radial RoadZamin Pallavaram, Chennai-600 043 Respondent Prayer: Appeal filed under Section 260A of the Income Tax Act, 1961 against the order of the Income Tax Appellate Tribunal “D” Bench, Chennai, dated 22.12.2023 in IT (TP) No.24/Chny/2022. T.C.A.No.105 of 2024: The Prl. Commissioner of Income tax-1,Chennai. Appellant Vs GE Power Conversion India Pvt. Ltd.,Plot No.29 (SP) __________Page 4 of 8 TCA Nos.100 to 106 of 2024 Thiru-Vi-Ka Industrial Estate,Ekkattuthangal, Guindy,Chennai-600 032. Respondent Prayer: Appeal filed under Section 260A of the Income Tax Act, 1961 against the order of the Income Tax Appellate Tribunal “D” Bench, Chennai, dated 22.12.2023 in IT (TP) No.5/Chny/2022. T.C.A.No.106 of 2024: The Prl. Commissioner of Income tax-1,Chennai. Appellant Vs BGR Boilers Pvt. Ltd.,443, Guna Building,Anna Salai, 6[th] Floor,Teynampet, Chennai-600 018. Respondent Prayer: Appeal filed under Section 260A of the Income Tax Act, 1961 against the order of the Income Tax Appellate Tribunal “D” Bench, Chennai, dated 22.12.2023 in IT (TP) No.22/Chny/2022. For AppellantMr.T.Ravikumarin all appeals:Sr. Standing Counsel __________Page 5 of 8 COMMON JUDGMENT(Delivered by the Hon'ble Chief Justice) Thiru-Vi-Ka Industrial Estate,Ekkattuthangal, Guindy,Chennai-600 032. Respondent Prayer: Appeal filed under Section 260A of the Income Tax Act, 1961 against the order of the Income Tax Appellate Tribunal “D” Bench, Chennai, dated 22.12.2023 in IT (TP) No.5/Chny/2022. T.C.A.No.106 of 2024: The Prl. Commissioner of Income tax-1,Chennai. Appellant Vs BGR Boilers Pvt. Ltd.,443, Guna Building,Anna Salai, 6[th] Floor,Teynampet, Chennai-600 018. Respondent Prayer: Appeal filed under Section 260A of the Income Tax Act, 1961 against the order of the Income Tax Appellate Tribunal “D” Bench, Chennai, dated 22.12.2023 in IT (TP) No.22/Chny/2022. For AppellantMr.T.Ravikumarin all appeals:Sr. Standing Counsel __________Page 5 of 8 COMMON JUDGMENT(Delivered by the Hon'ble Chief Justice) Counsels for assessees state the issue in these appeals is whether mentioning of DIN was mandatory. Counsels submitted that the issue is covered by a judgment of this Court, pronounced on 10.06.2025, in T.C.A.Nos.80 to 82 of 2025 [Commissioner of Income Tax, International Taxation, Chennai – 600 034 v. Sutherland Global Services Inc., C/o. Dhruva Advisors LLP, Prestige Terraces, 2nd Floor, Union Street, Infantry Road, Bengaluru], where the Court held that non-mentioning of the DIN or non-complying with the Circular No.19/2019, dated 14.08.2019, would __________Page 6 of 8 TCA Nos.100 to 106 of 2024 make the communication invalid. 2. Shri Ravikumar, in fairness, states that notices, which were subject matter of these appeals, were issued without DIN. Appeals are dismissed. There shall be no order as to costs. Consequently, interim applications are closed. (K.R.SHRIRAM, CJ.) (SUNDER MOHAN, J.) 01.07.2025 Index : Yes/NoNeutral Citation:Yes/Nobbr To: 1. The Assistant Registrar Income Tax Appellate Tribunal “D” Bench, Chennai. 2. The Deputy Commissioner of Income Tax, Corporate Circle 1(1), Chennai. __________Page 7 of 8 __________ Page 8 of 8 TCA Nos.100 to 106 of 2024 THE HON'BLE CHIEF JUSTICE ANDSUNDER MOHAN,J. bbr TCA Nos.100 to 106 of 2024 01.07.2025