Year-wise tax effect governs appeal maintainability under CBDT monetary limit circular; composite orders do not override the threshold.

Revenue appeals must be tested year-wise for monetary limit purposes, because tax effect is to be computed separately for each assessment year on the disputed issue. Where a Tribunal's common order covers multiple assessment years, the CBDT circular does not permit maintainability of an appeal for an assessment year in which the tax effect falls below the prescribed threshold. On that basis, the Gujarat HC held the Revenue's appeal not maintainable and disposed of it.

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Issues: Whether the Revenue's appeal was maintainable in view of the CBDT monetary limit circular when the tax effect in the relevant assessment year was below the prescribed threshold.

Analysis: The appeal arose from a common Tribunal order covering different assessment years. The Court noted that tax effect must be computed separately for each assessment year in respect of the disputed issue. The circular permits filing of appeals only for those assessment years in which the tax effect exceeds the monetary limit, and a composite order does not permit maintenance of an appeal where the relevant year's tax effect is below the threshold.

Conclusion: The appeal was not maintainable and was disposed of.

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