Tax effect threshold for each assessment year bars Revenue appeals despite a common order covering multiple years.

Revenue appeals were held not maintainable where the tax effect in the individual assessment years fell below the CBDT Circular No. 3/2018 monetary limit. The Tribunal applied the rule that tax effect is ordinarily to be computed separately for each assessment year, and rejected reliance on the composite-order exception because it could not deprive the assessee of the monetary threshold benefit when a common order covered multiple years. It also followed the binding High Court view that treating assessment years differently within one common order was discriminatory and contrary to Article 14. The appeals were dismissed.

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Issues: Whether the Revenue's appeals were maintainable where the tax effect in the individual assessment years was below the monetary limit prescribed in CBDT Circular No. 3/2018, notwithstanding that the assessments were covered by a common order and one year involved tax effect above the limit.

Analysis: The Tribunal applied the principle that the tax effect must ordinarily be computed separately for each assessment year. It noted that the exception in the circular for composite orders involving common issues could not be used to deny the assessee the benefit of the monetary limit where the individual assessment-year tax effect was below the prescribed threshold. The Tribunal relied on the binding High Court view that such differential treatment in common orders was discriminatory and offended Article 14 of the Constitution of India.

Conclusion: The appeals were held to be not maintainable and liable to be dismissed.

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