Low tax effect threshold bars pending revenue appeals; connected cross objections become infructuous when appeals are not maintainable.

Revenue appeals were not entertained because the tax effect in each matter was below the CBDT's revised monetary limit of Rs. 50 lakh under Circular No. 17/2019. The Tribunal applied the circular to pending appeals, relying on the subsequent clarification that the enhanced limits govern all pending matters. As the appeals were held non-maintainable on account of low tax effect, the connected cross objections ceased to have any surviving controversy and were treated as infructuous.

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Issues: Whether the Revenue's appeals were liable to be dismissed in view of the CBDT's enhanced monetary limit for filing appeals and whether the pending cross objections survived.

Analysis: The tax effect in each appeal was below the revised monetary limit of Rs. 50 lakh prescribed by CBDT Circular No. 17/2019 dated 08.08.2019. The Tribunal followed the view that the circular applied to pending appeals and noted the CBDT's subsequent clarification directing that the revised limits govern all pending matters. On that basis, the Revenue's appeals did not warrant entertainment. As the appeals themselves were not maintainable on account of low tax effect, the cross objections had no surviving controversy and became infructuous.

Conclusion: The Revenue's appeals were dismissed and the assessees' cross objections were treated as infructuous.

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