Low tax effect bar under CBDT circular led to dismissal of revenue appeals where no exception was shown.

Revenue appeals were held not maintainable where the tax effect in each matter fell below the monetary limit prescribed by the applicable CBDT circular. The circular barred continuation of such appeals unless a recognised exception applied, and no material was shown to bring the disputes within any exception clause. On that basis, the appeals were dismissed in limine for low tax effect.

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Issues: Whether the revenue's appeals were liable to be dismissed in limine on the ground that the tax effect was below the monetary limit prescribed by the applicable CBDT circular and no exception was shown to apply.

Analysis: The tax effect involved in each appeal was below the prescribed limit of Rs. 20 lakhs. The applicable circular barred the revenue from pursuing appeals of such low tax effect, subject to specified exceptions. No material was shown to bring the disputes within any exception, and the revenue could not demonstrate that the grounds raised attracted the exception clause.

Conclusion: The appeals were not maintainable and were dismissed in limine for low tax effect.

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