The Principal Commissioner Of Income Tax-1 v. Basf Catalysts India Pvt. Ltd
IN THE HIGH COURT OF JUDICATURE AT MADRAS
DATED: 01.07.2025 CORAM :
THE HON'BLE MR.K.R.SHRIRAM, CHIEF JUSTICE AND THE HON'BLE MR.JUSTICE SUNDER MOHAN and C.M.P.Nos.12681, 12685, 12689, 12700, 12699, 12703 and 12706 of T.C.A.No.100 of 2024:
BASF Catalysts India Pvt. Limited, P8/1, Mahindra World City, Paranur, Kanchipuram-603 002 dated 22.12.2023 in IT (TP) No.1/Chny/2023.
T.C.A.No.101 of 2024:
GU Oceans Pvt. Ltd., 3/381, 4th Floor, AKDR Tower, Rajiv Gandhi Salai (OMR) Mettukuppam, Chennai-600 097 dated 22.12.2023 in IT (TP) No.24/Chny/2023.
T.C.A.No.102 of 2024:
Groupon Shared Services Pvt. Ltd., Gopalan Global Axis SEZ Block, ABC G
Opposite Satya Sai Baba Hospital Plot No.152, EPIP Zone, Whitefield, Bangalore, Karnataka-560 056 dated 22.12.2023 in IT (TP) No.67/Chny/2022.
T.C.A.No.103 of 2024:
BGR Boilers Pvt. Ltd., 443, Guna Building, Anna Salai, 6th Floor Teynampet, Chennai-600 018.
dated 22.12.2023 in IT (TP) No.68/Chny/2022.
T.C.A.No.104 of 2024:
BNY Mellon Technology Pvt. Ltd., (formerly known as Inautix Technologies India P Ltd., Ground to Sixth Floor of Coral Block, 3, Survey No.181/183, No.158, Old No.153 Embassy Splendid Techzone, Embassy Property Development P Ltd., SNP Infrastructure, SEZ, 200 ft. Pallavaram, Thoraipakkam Radial Road Zamin Pallavaram, Chennai-600 043 dated 22.12.2023 in IT (TP) No.24/Chny/2022.
T.C.A.No.105 of 2024:
GE Power Conversion India Pvt. Ltd., Plot No.29 (SP)
Thiru-Vi-Ka Industrial Estate, Ekkattuthangal, Guindy, Chennai-600 032.
dated 22.12.2023 in IT (TP) No.5/Chny/2022.
T.C.A.No.106 of 2024:
BGR Boilers Pvt. Ltd., 443, Guna Building, Anna Salai, 6th Floor, Teynampet, Chennai-600 018.
dated 22.12.2023 in IT (TP) No.22/Chny/2022.
For Appellant in all appeals:
Mr.T.Ravikumar Sr. Standing Counsel
For Respondents in TCA Nos.100, 103, 104 and 106 of 2024:
Mr.N.V.Balaji For Respondent in TCA No.101 of 2024:
Mr.T.Banusekar and Mr.A.Sharren For Respondents in TCA Nos.102 and 105 of 2024:
Mr.R.Venkatanarayanan for M/s.Subbaraya Aiyar, Padmanabhan, Ramamani COMMON JUDGMENT (Delivered by the Hon'ble Chief Justice) Counsels for assessees state the issue in these appeals is whether mentioning of DIN was mandatory. Counsels submitted that the issue is covered by a judgment of this Court, pronounced on 10.06.2025, in T.C.A.Nos.80 to 82 of 2025 [Commissioner of Income Tax, International Taxation, Chennai - 600 034 v. Sutherland Global Services Inc., C/o. Dhruva Advisors LLP, Prestige Terraces, 2nd Floor, Union Street, Infantry Road, Bengaluru], where the Court held that non-mentioning of the DIN or non-complying with the Circular No.19/2019, dated 14.08.2019, would
make the communication invalid.
2. Shri Ravikumar, in fairness, states that notices, which were subject matter of these appeals, were issued without DIN. Appeals are dismissed. There shall be no order as to costs. Consequently, interim applications are closed. (K.R.SHRIRAM, CJ.) (SUNDER MOHAN, J.) 01.07.2025 Index :
Yes/No :
Yes/No bbr To:
1. The Assistant Registrar Income Tax Appellate Tribunal "D" Bench, Chennai.
2. The Deputy Commissioner of Income Tax, Corporate Circle 1(1),
THE HON'BLE CHIEF JUSTICE AND SUNDER MOHAN,J.
bbr 01.07.2025