CBDT monetary limits for departmental appeals apply to pending cases, leading to dismissal for low tax effect.

Departmental appeals before the ITAT were held not maintainable because the tax effect was below the monetary limit prescribed by the CBDT circular, as amended on 08.08.2019. The Tribunal followed coordinate bench reasoning that the enhanced limit applies to pending appeals as well as future ones, since the amendment continues the earlier litigation policy and merely raises the threshold for departmental litigation. As the appeals fell below the applicable limit, they were dismissed in limine and not examined on merits.

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Issues: Whether the Revenue appeals were maintainable in view of the CBDT circular prescribing monetary limits for departmental appeals and the subsequent amendment enhancing the limit, thereby warranting dismissal of the appeals.

Analysis: The tax effect involved in the appeals was below the monetary limit prescribed for appeals before the Appellate Tribunal under the CBDT circular as amended on 08.08.2019. The Tribunal followed the coordinate bench view that the amended circular applies not only to future appeals but also to pending appeals, since the amendment merely enhances the monetary limits and continues the earlier litigation policy. As the departmental appeals were below the threshold, they were treated as not maintainable.

Conclusion: The Revenue appeals were dismissed in limine for low tax effect and were not entertained on merits.

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