CBDT monetary limits for departmental appeals are binding, and audit-objection exceptions must be proved with material.

CBDT circulars prescribing monetary limits for departmental appeals remain binding on the Revenue, including the conditions attached to any exception. Where the Revenue seeks to rely on the audit-objection exception, it must produce cogent material showing that the objection was in fact accepted by the Department. A mere assertion that an audit objection existed is insufficient. As no supporting record was produced, the exception was not established and the appeal was not entertained.

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Issues: Whether the Revenue's appeal could be entertained despite the monetary limit prescribed by the CBDT circulars, and whether the exception relating to acceptance of a revenue audit objection was established.

Analysis: The appeal was sought to be saved by reliance on the later CBDT circular enhancing the monetary limit and on the exception carved out for cases where a revenue audit objection has been accepted by the Department. The Court held that the circulars continue to bind the Revenue, including the conditions attached to the exceptions. Mere assertion that an audit objection existed was insufficient; the Revenue was required to place material showing that the objection had in fact been accepted by the Department. No such record was produced.

Conclusion: The Revenue failed to establish that the exception to the monetary limit applied, and the appeal was not entertained.

Ratio Decidendi: CBDT circulars prescribing monetary limits for departmental appeals are binding on the Revenue, and any exception to such limits must be specifically proved by cogent material before the Court.

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