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Issues: Whether the department's appeals were maintainable in view of the CBDT's revised monetary limit for filing appeals before the Appellate Tribunal.
Analysis: The tax effect in the appeals was below the revised monetary threshold of Rs. 50,00,000 prescribed by CBDT Circular No. 17/2019 dated 08.08.2019, which enhanced the limit for departmental appeals before the Appellate Tribunal. The circular required the tax effect to be computed separately for each assessment year and permitted filing only where the disputed tax effect exceeded the prescribed limit. Since the present appeals did not meet that threshold, they were covered by the circular and were not maintainable.
Conclusion: The appeals were held to be not maintainable and were dismissed.
Final Conclusion: The departmental appeals failed at the threshold on the ground of low tax effect under the CBDT monetary limit policy.
Ratio Decidendi: Departmental appeals are not maintainable where the tax effect falls below the applicable CBDT monetary limit, and the tax effect must be applied assessment year-wise.