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<h1>Madras High Court Rules Section 140A(3) of Income Tax Act Unconstitutional; CBDT to Appeal to Supreme Court.</h1> The Madras High Court has deemed Section 140A(3) of the Income Tax Act, 1961 unconstitutional. The Central Board of Direct Taxes (CBDT) has not accepted this decision and is seeking to appeal to the Supreme Court. The Ministry of Law has noted that the High Court's judgment may be flawed, as it treats tax arrears as merely civil liabilities and overlooks the quasi-criminal nature of penalties for willful default. The recommendation is to pursue the appeal vigorously and consider amending the Act only if the Supreme Court upholds the High Court's ruling.