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 T.C.A.No.659 of 2014 ---------------------------- J U D G M E N T (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. 2/4 https://www.mhc.tn.gov.in/judis T.C.A.No.659 of 2014 ---------------------------- 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. 3/4 https://www.mhc.tn.gov.in/judis T.C.A.No.659 of 2014 ---------------------------- S.M.SUBRAMANIAM, J. and C.SARAVANAN, J. dsa T.C.A.No. 659 of 2014 04.09.2025 4/4 https://www.mhc.tn.gov.in/judis