The Commissioner of Income-tax, Chennai v. P.R.Manickam
[Citation -2020-LL-0707-12]
| Citation | 2020-LL-0707-12 |
|---|---|
| Appellant Name | The Commissioner of Income-tax, Chennai |
| Respondent Name | P.R.Manickam |
| Court | HIGH COURT OF MADRAS |
| Relevant Act | Income-tax |
| Date of Order | 07/07/2020 |
| Assessment Year | 1985-86, 1986-87, 1987-88, 1988-89, 1989-90, 1990-91, 1991-92, 1992-93, 1993-94, 1994-95 |
| Judgment | View Judgment |
| Keyword Tags | satisfaction note • tax liability • low tax effect |
| Bot Summary: | 4/Mds/2009 on the file of the Income Tax Appellate Tribunal, Madras C Bench, Chennai, for the assessment period 01.04.1985 to 31.03.1995 and 01.04.1995 to 29.09.1995. This appeal, filed by the Revenue under Section 260A of the Income Tax Act, 1961 is directed against the order dated 07.09.2012 made in M.P.No. The Tax case appeal was admitted on 17.09.2013 on the following substantial questions of law : 1.Whether on the facts and in the circumstances of the case, the Income Tax Appellate Tribunal was right in holding that Section 158BD proceedings were imitated without recording necessary satisfaction which is contrary to be noting in the order sheet dated 16.08.1996 wherein satisfaction has been recorded by the proper officer at the time of initiating notice under Section 158BD 2. Whether on the facts and in the circumstances of the case, the Income Tax Appellate Tribunal was right in quashing the assessment and holding that there was no satisfaction which is contrary to the records 3. The matter has been listed under the caption For Withdrawal on account of low tax effect. We verified the case bundle, more particularly, the order passed by the Assessing Officer dated 31.12.2008, and we find that the Tax liability is below the threshold limit fixed in the circular dated 08.8.2019 in Circular No.17/2019 issued by the Central Board of Direct Taxes. Accordingly, the tax case appeal is dismissed on the ground of low tax effect. |