Low tax effect limits bar revenue appeals where CBDT circular thresholds are not met and no exception applies.

Revenue appeals are not maintainable where the disputed tax effect falls below the monetary limit prescribed by the applicable CBDT circulars, including Circular No. 17/2019 enhancing the limit set by Circular No. 3/2018. Where no exception to the circular is shown and the Department cannot dispute the tax-effect calculation, the appeal is dismissed as barred by the low-tax-effect policy.

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Issues: Whether the revenue's appeal was maintainable in view of the low tax effect under the applicable CBDT circulars.

Analysis: The tax effect involved in the disputed quantum additions was below the monetary limit prescribed by Circular No. 17/2019, which enhanced the limit fixed by Circular No. 3/2018. No exception to the circular was shown to apply, and the Department could not controvert the factual position regarding the tax effect.

Conclusion: The appeal was not maintainable and was dismissed.

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