CBDT monetary limit for tax appeals applies retrospectively, making low-tax-effect departmental appeals not maintainable.

CBDT Circular No. 21 of 2015 enhanced the monetary threshold for filing departmental appeals and applied retrospectively to pending matters. Where the tax effect falls below the prescribed limit, appeals before the Tribunal are to be withdrawn or not pursued. On that basis, the Revenue's appeal was held not maintainable and dismissed without consideration of the merits.

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Issues: Whether the Revenue's appeal was liable to be dismissed in view of the CBDT circular prescribing a monetary limit for filing appeals where the tax effect was below the prescribed threshold.

Analysis: The appeal involved tax effect below Rs. 10,00,000. Circular No. 21 of 2015 dated 10.12.2015 enhanced the monetary limit and applied retrospectively to pending appeals. The circular directed withdrawal or non-pursuit of appeals before the Tribunal where the tax effect was below the prescribed limit.

Conclusion: The appeal was not maintainable and was dismissed without examination on merits.

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