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Issues: Whether the Revenue's appeal was maintainable in view of the monetary limit prescribed by CBDT instructions for departmental appeals.
Analysis: The disputed tax effect was below the prescribed threshold. The Tribunal relied on the consistent departmental-appeal instructions issued by CBDT from time to time, which restricted filing of appeals before the Appellate Tribunal where the tax effect did not satisfy the monetary limit. On that basis, the appeal was found to be not maintainable.
Conclusion: The Revenue's appeal was held to be not maintainable and was dismissed in limine.
Final Conclusion: The decision affirms that departmental appeals below the prescribed tax-effect limit are not entertainable before the Tribunal.
Ratio Decidendi: A departmental appeal is not maintainable where the tax effect falls below the monetary limit prescribed by binding CBDT instructions.