Commissioner Of Income Tax vs M/S.Sri Renuga Textiles Ltd
2025 Latest Caselaw 6752 Mad

Madras High Court

Commissioner Of Income Tax vs M/S.Sri Renuga Textiles Ltd on 4 September, 2025

Author: S.M.Subramaniam

Bench: S.M.Subramaniam, C.Saravanan

                                                                                        T.C.A.No.659 of 2014
                                                                                       ----------------------------
                                  THE HIGH COURT OF JUDICATURE AT MADRAS
                                                 DATED: 04.09.2025
                                                         CORAM:
                              THE HONOURABLE MR.JUSTICE S.M.SUBRAMANIAM
                                                 AND
                                 THE HONOURABLE MR.JUSTICE C.SARAVANAN

                                               T.C.A.No.659 of 2014


                Commissioner of Income Tax,
                Chennai.                                                               ...Appellant



                                                              Vs.

                M/s.Sri Renuga Textiles Ltd.,
                87 Cumbum Road,
                P.C.Pati, Theni – 652 531.                                             ...Respondent


                PRAYER: Tax Case Appeal filed under Section 260A of the Income Tax Act,
                1961 against the order of the Income Tax Appellate Tribunal, “C” Bench,
                Chennai, dated 21.11.2013 made in ITA.No.1009(Mds)/2012.

                                      For Appellant           : Mr.V.Mahalingam


                                      For Respondent          : Mr.G.Baskar


                                                           *****




                1/4


https://www.mhc.tn.gov.in/judis              ( Uploaded on: 09/09/2025 11:35:43 am )
                                                                                          T.C.A.No.659 of 2014
                                                                                         ----------------------------
                                                    JUDGMENT

(Judgment of the Court was delivered by S.M.SUBRAMANIAM, J.)

This Tax Case Appeal has been filed by the Commissioner of Income Tax

calling in question the correctness of the order passed by the Income Tax

Appellate Tribunal, “C” Bench, Chennai, by raising the following substantial

question of law:-

“Whether on facts and circumstances of the case, the Tribunal was justified in quashing the order of the CIT under Section 263 of the Act, by holding that the assessing officer had taken one of the possible views that the income from sale of carbon credits is a revenue income, and therefore the assessment is not erroneous on the issue of deduction granted under Section 80 IA with respect to income from sale of the carbon credit? ”

2. It is brought to our notice by the learned Standing Counsel for the

appellant Revenue that in the instant case, as per the CBT's Circular No.9 of

2024 dated 17.09.2024 the tax effect is said to be less than the monetary limit

imposed and therefore, the appeal can be disposed of, keeping the substantial

questions of law raised in this appeal open for adjudication at a later point of

time.

https://www.mhc.tn.gov.in/judis ( Uploaded on: 09/09/2025 11:35:43 am )

----------------------------

3. Recording the said submission, this Tax Case Appeal is dismissed for

low tax effect, keeping open the substantial questions of law for adjudication at

appropriate stage. No costs.

                                                                            (S.M.S., J.)       (C.S.N., J.)
                                                                                      04.09.2025
                dsa

                Internet         :Yes/No
                Index            :Yes/No
                Neutral Citation :Yes/No
                Speaking/Non-speaking order

                To:

                M/s.Sri Renuga Textiles Ltd.,
                87 Cumbum Road,
                P.C.Pati, Theni – 652 531.







https://www.mhc.tn.gov.in/judis              ( Uploaded on: 09/09/2025 11:35:43 am )

                                                                                  ----------------------------
                                                                        S.M.SUBRAMANIAM, J.
                                                                                        and
                                                                             C.SARAVANAN, J.

                                                                                                        dsa









                                                                                           04.09.2025

https://www.mhc.tn.gov.in/judis ( Uploaded on: 09/09/2025 11:35:43 am )