T.C.A.No.59 of 2025 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 11.09.2025 CORAM : THE HONOURABLE MR. MANINDRA MOHAN SHRIVASTAVA, CHIEF JUSTICE AND THE HONOURABLE MR.JUSTICE G.ARUL MURUGAN T.C.A.No.59 of 2025 and C.M.P.No.6937 of 2025 Commissioner of Income Tax International Taxation, Chennai - 600 034. Appellant Vs EOS GmbH India Branch Office No. 36, Ground Floor, Sivananda Nagar, Kolathur, Chennai – 600 009. Respondent PRAYER : Appeal filed under Section 260A of the Income-tax Act, 1961 against the order of the Income Tax Appellate Tribunal, Madras “D” Bench, dated 22.12.2023 in IT (TP) A No.16/Chny/2021. ______________ https://www.mhc.tn.gov.in/judis T.C.A.No.59 of 2025 For Appellant: Mr.Dinesh for Mr.Karthik Ranganathan [Through VC] JUDGMENT (Delivered by the Hon'ble Chief Justice) Heard Mr.Dinesh, learned counsel for the appellant/Revenue, who is appearing through video-conferencing. 2. Mr.Dinesh, learned counsel for the appellant, on instructions from Mr.Karthik Ranganathan, learned Senior Standing Counsel, fairly submits that it is a case having low tax effect. Therefore, in view of the Circular No.05/2024 dated 15.03.2024, and Circular No.09/2024, dated 17.09.2024, issued by the Ministry of Finance, Department of Revenue, Central Board of Direct Taxes, Government of India, the appellant/Revenue does not wish to proceed with the matter, though the question of law may be kept open for consideration in the appropriate matter. ______________ https://www.mhc.tn.gov.in/judis T.C.A.No.59 of 2025 In that view of the matter, the appeal stands dismissed. There shall be no order as to costs. Consequently, interim application stands closed. (MANINDRA MOHAN SHRIVASTAVA, CJ) (G.ARUL MURUGAN,J) 11.09.2025 Index : Yes/No Neutral Citation : Yes/No sasi To: 1. The Assistant Registrar Income Tax Appellate Tribunal Chennai Benches, Chennai. 2. The Joint Commissioner of Income Tax (HQ) and Secretary, Dispute Resolution Panel-2 A Wing, 4th Floor, Kendriya Sadan Koramangala, Bengaluru – 560 034. ______________ https://www.mhc.tn.gov.in/judis T.C.A.No.59 of 2025 THE HON'BLE CHIEF JUSTICE AND G.ARUL MURUGAN,J. (sasi) T.C.A.No.59 of 2025 11.09.2025 ______________ https://www.mhc.tn.gov.in/judis