Madras High Court
The Prl. Commissioner Of Income Tax vs Basf Catalysts India Pvt. Limited on 1 July, 2025
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.
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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, 4th 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
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TCA Nos.100 to 106 of 2024
Opposite Satya Sai Baba Hospital
Plot 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, 6th 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.68/Chny/2022.
T.C.A.No.104 of 2024:
The Prl. Commissioner of Income tax-1,
Chennai.
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TCA Nos.100 to 106 of 2024
Appellant
Vs
BNY Mellon Technology Pvt. Ltd.,
(formerly known as Inautix Technologies
India P Ltd.,
Ground to Sixth Floor of Coral Block,
3, Survey No.181/183, No.158, Old No.153
Embassy Splendid Techzone,
Embassy Property Development P Ltd.,
SNP Infrastructure, SEZ,
200 ft. Pallavaram,
Thoraipakkam Radial Road
Zamin 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)
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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, 6th 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 Appellant Mr.T.Ravikumar
in all appeals: Sr. Standing Counsel
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TCA Nos.100 to 106 of 2024
For Respondents Mr.N.V.Balaji
in TCA Nos.100,
103, 104 and 106 of
2024:
For Respondent in Mr.T.Banusekar
TCA No.101 of and Mr.A.Sharren
2024:
For Respondents in Mr.R.Venkatanarayanan
TCA Nos.102 and for M/s.Subbaraya Aiyar,
105 of 2024: Padmanabhan, Ramamani
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
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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/No
Neutral Citation : Yes/No
bbr
To:
1. The Assistant Registrar
Income Tax Appellate Tribunal
“D” Bench, Chennai.
2. The Deputy Commissioner of Income Tax,
Corporate Circle 1(1),
Chennai.
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TCA Nos.100 to 106 of 2024
THE HON'BLE CHIEF JUSTICE
AND
SUNDER MOHAN,J.
bbr
TCA Nos.100 to 106 of 2024
01.07.2025
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