Monetary limit for Revenue appeals applies to pending matters, making appeals below the tax effect threshold non-maintainable.

A departmental instruction prescribing a monetary limit for Revenue appeals bars filing where the tax effect is below the threshold, and the same limit applies to pending proceedings. On that basis, a Revenue appeal falling below the prescribed tax effect was treated as not maintainable and dismissed. The operative principle is that such appeal instructions govern maintainability in pending matters as well, preventing entertainment of appeals under the threshold.

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Issues: Whether the Revenue's appeal was maintainable when the tax effect was below the monetary limit prescribed by Instruction No. 3/2011 and whether that instruction applied to pending proceedings.

Analysis: The monetary limit fixed by the departmental instruction barred filing of an appeal where the tax effect was below the prescribed threshold. The Court also followed the view that the instruction governed pending matters as well. On that basis, the appeal could not be entertained.

Conclusion: The Revenue's appeal was held to be not maintainable and was dismissed.

Ratio Decidendi: A departmental instruction prescribing a monetary limit for appeals applies to pending proceedings and renders a Revenue appeal not maintainable where the tax effect is below the threshold.

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