Board-issued monetary limits for appeals do not create acquiescence; tax authorities may later pursue the same issue on appeal. Section 268A authorises the Board to issue orders, instructions or directions fixing monetary limits to regulate filing of appeals or applications for reference by income-tax authorities. Non-filing under those administrative limits does not prevent the authority from later filing appeals on the same issue for other assessment years or against other assessees. An assessee cannot contend that the authority has acquiesced by not filing, and tribunals or courts must have regard to the Board's orders and the circumstances of filing or non-filing when hearing such appeals or references.
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Provisions expressly mentioned in the judgment/order text.
Board-issued monetary limits for appeals do not create acquiescence; tax authorities may later pursue the same issue on appeal.
Section 268A authorises the Board to issue orders, instructions or directions fixing monetary limits to regulate filing of appeals or applications for reference by income-tax authorities. Non-filing under those administrative limits does not prevent the authority from later filing appeals on the same issue for other assessment years or against other assessees. An assessee cannot contend that the authority has acquiesced by not filing, and tribunals or courts must have regard to the Board's orders and the circumstances of filing or non-filing when hearing such appeals or references.
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