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Issues: Whether the revenue appeal was liable to be entertained in view of the CBDT instructions prescribing monetary limits for departmental appeals where the tax effect was below the prescribed threshold.
Analysis: The appeal challenged deletion of additions made under sections 68 and 69C of the Income-tax Act, 1961, but the tax effect was stated to be less than Rs. 2 lakhs. The Board's instruction fixing monetary limits for appeals before the Tribunal was relied upon as a binding policy measure intended to reduce litigation. The order also referred to judicial recognition that such circulars bind the revenue and apply to pending matters.
Conclusion: The appeal was not to be entertained and was dismissed in limine as the tax effect was below the prescribed monetary limit.