Monetary limit for tax appeals bars low-tax-effect cases, with revised CBDT circular applying to pending matters

Revenue appeals were held not maintainable because the tax effect in each matter fell below the CBDT's revised monetary limit of Rs. 20 lakhs. The circular was applied retrospectively to pending appeals and replaced earlier instructions. None of the recognised exceptions applied, including challenges to constitutional validity, a rule, or the legality of a Board order, notification, instruction, or circular. The appeals were therefore dismissed on the basis of the monetary threshold governing maintainability.

---

---

Issues: Whether the Revenue's appeals were maintainable in view of the CBDT circular prescribing a monetary limit based on tax effect.

Analysis: The tax effect in each appeal was below the revised monetary limit of Rs. 20 lakhs. The circular relied upon superseded earlier instructions and applied to pending appeals retrospectively. The case did not fall within any of the stated exceptions, such as constitutional validity, challenge to a rule, or illegality of a Board order, notification, instruction or circular.

Conclusion: The appeals were not maintainable and were dismissed.

---