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Issues: Whether the Department's appeal was maintainable in view of the CBDT monetary limit, when the tax effect was below the prescribed threshold.
Analysis: The appeal was filed after the issuance of CBDT Instruction No. 3/2011, which prescribed a monetary limit of Rs. 3,00,000 for filing appeals before the Appellate Tribunal. The tax effect in the present appeal was Rs. 2,33,155, which was below the prescribed limit. The instruction, issued under section 268A(1) of the Income-tax Act, 1961, applied to the appeal and barred its filing on account of low tax effect.
Conclusion: The Department's appeal was not maintainable and was dismissed.