CBDT monetary limit bars departmental appeals below threshold, and the later circular applies to pending matters.

Departmental appeals before the ITAT were held not maintainable because the tax effect in each appeal fell below the CBDT-prescribed monetary threshold. The later CBDT Circular No. 03/2018 was applied retrospectively to pending appeals, superseding Circular No. 21/2015, so the appeals did not meet the continuation threshold. On that basis, the Revenue's challenges were dismissed in limine for low tax effect.

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Issues: Whether the Revenue appeals were maintainable in view of the CBDT monetary limit for filing appeals before the Tribunal, and whether the later circular applied to pending appeals.

Analysis: The tax effect in each appeal was below the monetary limit of Rs. 20 lakh prescribed by CBDT Circular No. 03/2018 dated 11/07/2018, which superseded Circular No. 21/2015 dated 10/12/2015. The circular was treated as applicable retrospectively to pending appeals, and therefore the appeals did not satisfy the prescribed threshold for continuation before the Tribunal.

Conclusion: The Revenue appeals were held to be not maintainable and were dismissed in limine.

Final Conclusion: The appeals could not be entertained on account of low tax effect, resulting in dismissal of the Revenue's challenges.

Ratio Decidendi: Departmental appeals below the CBDT-prescribed monetary threshold are not maintainable, and the applicable circular governs pending appeals retrospectively.

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