2025:MHC:2974

IN THE HIGH COURT OF JUDICATURE AT MADRAS

DATED: 19.12.2025

CORAM :

THE HONOURABLE DR.JUSTICEANITA SUMANTH

and

THE HONOURABLE MRS.JUSTICE K.GOVINDARAJAN

THILAKAVADI

T.C.A.No. 224 of 2014

The Commissioner of Income Tax,

Chennai. .. Appellant

vs

M/s. Cognizant Technology Solutions India Pvt ltd ,

30, Whites Road,

Chennai - 600 014 . .. Respondent

Prayer : Appeal filed under Section 260-A of the Income-Tax Act against the order of the Income-Tax Appellate Madras “C” Bench, Chennai dated

10.02.2012 passed in ITA No.1921/Mds/2010.

For Appellant : Mr.R.Karthik

For Respondent : Mr.Vikram Vijayaraghavan

for M/s Subbaraya Aiyar Padmanabhan

JUDGMENT the provisions of the Income-Tax Act, 1961 (Act).

(Delivered by Dr. ANITA SUMANTH, J.)

The Revenue is in appeal as against the order of the Income-Tax

Appellate Tribunal (Tribunal / ITAT) dated 10.02.2012, passed in terms of

2. The questions of law that have been admitted on 22.08.2014 are as follows:-

“1.Whether on the facts and in the circumstances of the case, the Income Tax Appellate Tribunal was right in holding that reopening of the assessment was not proper and quashed the assessment proceedings?

2. Whether on the facts and in the circumstances of the