HONOURABLE MR. MANINDRA MOHAN SHRIVASTAVA, CHIEF JUSTICE AND THE HONOURABLE MR.JUSTICE G.ARUL MURUGAN T.C.A.No.223 of 2025 CES ONYX Pvt. Ltd., rep. By its Authorised Signatory/ Director Prerna Razdan Zijoo 46-B, IV Floor, Krishnan Complex South Boag Road, T.Nagar Chennai-600 017 Appellant Vs The Assistant Commissioner of Income Tax Company Circle-1(3) Chennai. Respondent For Appellant: Mr.V.S.Jayakumar Senior Counsel for Mr.N.S.Amogh Simha For Respondent: Mr.S.Abubacker Sidhic Jr. Standing Counsel

[13/11, 18:27] Sekarreporter: IN THE HIGH COURT OF JUDICATURE AT MADRAS
DATED: 12.11.2025
CORAM
THE HONOURABLE MR. MANINDRA MOHAN SHRIVASTAVA, CHIEF JUSTICE AND THE HONOURABLE MR.JUSTICE G.ARUL MURUGAN
T.C.A.No.223 of 2025
CES ONYX Pvt. Ltd.,
rep. By its Authorised Signatory/ Director Prerna Razdan Zijoo
46-B, IV Floor, Krishnan Complex
South Boag Road, T.Nagar
Chennai-600 017
Appellant Vs
The Assistant Commissioner of Income Tax Company Circle-1(3) Chennai.
Respondent For Appellant:
Mr.V.S.Jayakumar Senior Counsel for Mr.N.S.Amogh Simha
For Respondent:
Mr.S.Abubacker Sidhic
Jr. Standing Counsel
ORDER
(Order of the Court was made by the Hon’ble Chief Justice)
This appeal is admitted on the following substantial question of
law:
“Whether the Tribunal was correct in law that upon a proper construction of the scope of work as described in Clause 2 of the concession agreement dated 26.11.1999, the project activities carried out by the appellant fall within the meaning of “infrastructure facility” namely, sanitation and sewerage system or “Solid Waste Management System” as envisaged in Clause (c) of the Explanation to Clause (i) of subsection (4) of Section 80-1A of the Income Tax Act, 1961 entitling the appellant to the deduction under the said Section?”
2. Mr.S.Abubacker Sidhic, learned Junior Standing Counsel, takes
notice for respondent/Revenue.
3. Copy of appeal memo, along with substantial question of law framed, be supplied by the appellant to learned counsel for the Revenue.
List the appeal for final hearing.
(MANINDRA MOHAN SHRIVASTAVA,CJ) (G.ARUL MURUGAN,J)
12.11.2025
bbr
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