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Issues: Whether the departmental circular fixing a monetary limit for filing and pursuing appeals applied to pending revenue appeals where the tax effect was below the prescribed threshold.
Analysis: The Tribunal noted that the circular relied upon by the assessee raised the monetary limit to Rs. 2 lakhs and was intended to reduce litigation. It accepted the view that such instructions govern pending matters as well, particularly where the tax effect in each appeal is below the prescribed limit. The Tribunal treated the revised monetary limit as applicable to the revenue appeals then pending before it.
Conclusion: The circular applied to the pending appeals, and the revenue appeals were not maintainable since the tax effect in each was below Rs. 2 lakhs.