Low-tax-effect revenue appeals barred under CBDT circular where no applicable exception was shown

Revenue appeals with tax effect below the monetary limit in CBDT Circular No. 3/2018 were treated as barred from further prosecution unless a specified exception applied. The Tribunal found that no exception under paragraph 10 of the circular was shown on the record, and a request for time to obtain a certificate did not change that position. As the available material did not establish maintainability, the appeals were dismissed in limine for want of compliance with the circular's low-tax-effect threshold.

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Issues: Whether the revenue's appeals were barred by the monetary limit prescribed in CBDT Circular No. 3/2018 dated 11.07.2018 and were liable to be dismissed in limine.

Analysis: The tax effect involved in each appeal was below Rs. 20 lakhs. The circular in force prohibited the revenue from pursuing such appeals unless the case fell within one of the specified exceptions. On the material before the Tribunal, no exception under paragraph 10 of the circular was shown to apply. The request for time to obtain a certificate did not alter the position, as the available record did not disclose any exception.

Conclusion: The appeals were not maintainable in view of the low tax effect and were dismissed in limine.

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