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[Cites 3, Cited by 0]

Madras High Court

Commissioner Of Income Tax vs M/S. Sical Logistics Ltd on 14 November, 2024

Author: Anita Sumanth

Bench: Anita Sumanth

    2025:MHC:4320


                                                               T.C.A.Nos.894 of 2010, 695,696 & 71 of 2013


                              IN THE HIGH COURT OF JUDICATURE AT MADRAS

                                               DATED: 14.11.2024

                                                     CORAM :

                             THE HONOURABLE DR.JUSTICE ANITA SUMANTH
                                               and
                            THE HONOURABLE MR.JUSTICE G. ARUL MURUGAN

                                  T.C.A.Nos. 894 of 2010, 695, 696 & 71 of 2013
                                                      and
                                               M.P.No.1 of 2013

                     T.C.A.No.894 of 2010

                     Commissioner of Income Tax,
                     Chennai                                                             .. Appellant

                                                       vs

                     M/s. SICAL Logistics Ltd.,
                     (Formerly M/s.South India Corporation (Agencies) Ltd),
                     73, Armenian Street, Chennai 600 001.                             .. Respondent

                     T.C.A.Nos.695 & 696 of 2013

                     The Commissioner of Income Tax,
                     Chennai.                                                            .. Appellant

                                                       vs

                     M/s. Sical Logistics Limited
                     73, Armenian Street,
                     Chennai – 600 001.                                                .. Respondent

                     T.C.A.NO.71 of 2013

                     M/s. Sical Logistics Limited,
https://www.mhc.tn.gov.in/judis
                     1/5
                                                                   T.C.A.Nos.894 of 2010, 695,696 & 71 of 2013


                     73-A, Armenian Street,
                     Chennai – 600 001
                     PAN AAACS 3789 B                                                        .. Appellant

                                                              vs

                     The Assistant Commissioner of Income Tax
                     Company Circle V(1),
                     Chennai.                                                              .. Respondent


                     Prayer in T.C.A.No.894 of 2006: Appeal filed under Section 260A of the
                     Income Tax Act, 1961 against order of the Income Tax Appellate
                     Tribunal, Madras 'C' Bench, dated 27.11.09 in I.T.A.No.1280/Mds/2006.

                     Prayer in T.C.A.No.695 of 2013: Appeal filed under Section 260A of the
                     Income Tax Act, 1961 against order of the Income Tax Appellate
                     Tribunal,    Madras     'C'    Bench,      dated     18.10.2010     in
                     I.T.A.No.534/Mds/2009.

                     Prayer in T.C.A.No.696 of 2013: Appeal filed under Section 260A of the
                     Income Tax Act, 1961 against order of the Income Tax Appellate
                     Tribunal,    Madras     'C'    Bench,      dated     18.10.2010     in
                     I.T.A.No.1626/Mds/2009.

                     Prayer in T.C.A.No.71 of 2013: Appeal filed under Section 260A of the
                     Income Tax Act, 1961 against order of the Income Tax Appellate
                     Tribunal,    Chennai     'A'   Bench,      dated    08.05.2012     in
                     I.T.A.No.391/Mds/2012.

                           Case Number        For Appellant            For Respondent
                           T.C.A.No.894     of Mr.T.Ravikumar          Mr.R.Venkata Narayanan
                           2010                Senior Standing Counsel for M/s.Subbaraya Aiyar
                                                                       Padmanabhan Ramamani
                           T.C.A.Nos. 695   & Mr.T.Ravikumar          Mr.R.Venkata Narayanan
                           696 of 2013        Senior Standing Counsel
                           T.C.A.No.71 of 2013 Mr.R.Sivaraman          Mr.T.Ravi Kumar
                                                                       Senior Standing Counsel


https://www.mhc.tn.gov.in/judis
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                                                                      T.C.A.Nos.894 of 2010, 695,696 & 71 of 2013


                                                  COMMON JUDGMENT

(Delivered by Dr. ANITA SUMANTH.,J) Heard Mr.Ravikumar, learned Senior Standing Counsel, who appears for the Income Tax Department in all these matters and Mr.R.Venkata Narayanan, learned counsel for the respondent in some of the matters.

2. Learned counsel for the petitioner reports no instructions. The assessee / M/s.Sical Logistics Limited has undergone Corporate Insolvency Resolution Process in IA(IBC)/102(CHE)/2022 in IBA/73/2020 and has been wound up by order passed by the National Company Law Tribunal, Chennai dated 08.12.2022. The operative portion of order dated 08.12.2022 is as follows:-

“28. Subject to the observations made in this Order, the Resolution Plan in question is hereby APPROVED by this Adjudicating Authority. The Resolution Plan shall form part of this Order. The Resolution Plan is binding on the Corporate Debtor and other stakeholders involved so that the revival of the Debtor Company shall come into force with immediate effect. The Moratorium imposed under Section 14 shall cease to have effect from the date of this Order.”

3.Mr.Ravikumar, circulates two claims in Form B (proof of claim by operational creditors except workmen and employees both dated 30.09.2022). He is unaware whether the demand under the present tax https://www.mhc.tn.gov.in/judis 3/5 T.C.A.Nos.894 of 2010, 695,696 & 71 of 2013 case appeals would stand subsumed in those two claims.

4.However and since neither parties can throw any more light on this aspect of the matter, these Tax Case Appeals are closed returning the substantial questions of law unanswered. The parties are at liberty to work out their claims qua the resolution plan formulated and should there be any necessity, to revive the tax case (appeal), such liberty is granted to the parties. No costs.

[A.S.M., J] [G.A.M., J] 14.11.2024 Index:Yes/No Speaking order Neutral Citation:Yes vs To The Assistant Commissioner of Income Tax Company Circle V(1), Chennai.

https://www.mhc.tn.gov.in/judis 4/5 T.C.A.Nos.894 of 2010, 695,696 & 71 of 2013 DR. ANITA SUMANTH.,J.

and G. ARUL MURUGAN.,J.

vs T.C.A.Nos. 894 of 2010, 695, 696 & 71 of 2013 14.11.2024 https://www.mhc.tn.gov.in/judis 5/5