Low tax effect bar on revenue appeals applies to pending proceedings, making the appeal not maintainable.

Revenue appeals were barred where the tax effect fell below the prescribed monetary limit under Instruction No. 3/2011, and the instruction applied to pending proceedings as well. Because the tax effect was below the threshold, the High Court held that the appeal could not be entertained and dismissed it as not maintainable.

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Issues: Whether the Revenue's appeal was maintainable in view of the low tax effect and the applicable departmental instruction barring filing of appeals where the tax effect was below the prescribed monetary limit.

Analysis: The tax effect involved was below Rs. 10,00,000. Instruction No. 3/2011 prohibited filing of an appeal to the High Court where the tax effect was less than the prescribed limit. The Court also noted that the instruction applied to pending proceedings. On that basis, the appeal could not be entertained.

Conclusion: The Revenue's appeal was held to be not maintainable and was dismissed.

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