Revenue appeal against Tribunal's order setting aside Section 14A/Rule 8D disallowance was dismissed for low tax effect per CBDT Circular No.9 of 2024, with substantial questions of law kept open. No substantive adjudication occurred.
Appeal dismissed for low tax effect, no costs; substantial questions of law kept open.
This page shows the compact analysis of this judgement. The full analysis — procedural history, issue-by-issue holdings with ratio and obiter, advocates, and paragraph-level evidence for every claim — is being added to the record in batches and will appear here when this judgement has been through it.
T.C.A.No.256 of 2024
I N THE HIGH COURT OF JUDICATURE AT MADRAS
DATED: 05.11.2024
CORAM
THE HON'BLE MR.JUSTICE R.SURESH KUMAR AND THE HON'BLE MR.JUSTICE C.SARAVANAN
Tax Case Appeal No.256 of 2024
Principal Commissioner of Income Tax Chennai.
.... Appellant
Vs.
Sudhershan Rani Rallan
.... Respondent
Tax Case Appeal filed under Section 260A of the Income Tax Act, 1961 against the order of the Income Tax Appellate Tribunal, 'B' Bench Chennai, dated 27.06.2023 made in I.T.A.No.131/Chny/2022.
For Appellant : Mr.J.Narayanaswamy Senior Standing Counsel
J U D G M E N T
(Delivered by R.SURESH KUMAR, J.)
This Tax Case Appeal has been filed by the Revenue calling in question
the correctness of the order passed by the Income Tax Appellate Tribunal, Chennai by raising the following substantial questions of law:
T.C.A.No.256 of 2024
T.C.A.No.256 of 2024
Counsel for the appellant Revenue, this Tax Case Appeal is dismissed for low tax effect, keeping open the substantial questions of law for adjudication at appropriate stage. No costs.
(R.S.K.,J.) (C.S.N.,J.) 05.11.2024
NCS : Yes/No KST
To
The Income Tax Appellate Tribunal 'B' Bench, Chennai.
T.C.A.No.256 of 2024
R.SURESH KUMAR, J. AND C.SARAVANAN, J.
KST
T.C.A.No.256 of 2024
05.11.2024
3 provisions across 2 enactments
Principal Commissioner of Income Tax Chennai
Sudhershan Rani Rallan
R.Suresh Kumar
C.Saravanan
As recorded by the court registry
Judgements on the same questions, provisions and authorities, from every court
