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Issues: Whether the Revenue's appeal was maintainable in view of the low tax effect and the applicable CBDT monetary limit circular.
Analysis: The appeal was examined only on the question of maintainability, as the tax effect was below the threshold then applicable. The Court noted the later CBDT Circular No. 3/2018 dated 11.07.2018, which enhanced the monetary limit for filing and pursuing appeals before the High Courts to Rs. 50,00,000/-. On that basis, the Revenue could not continue with the appeal.
Conclusion: The appeal was not maintainable and could not be pursued by the Revenue.
Final Conclusion: The Revenue's challenge failed at the threshold on account of the monetary limit policy governing tax appeals.