Monetary limit for tax appeals applies in writ matters too; Revenue cannot bypass the threshold because no alternative remedy existed.

Where the tax effect is below the prescribed monetary threshold, a departmental appeal will not be entertained merely because the dispute arose in writ jurisdiction and the assessee had no alternative statutory remedy under the Income-tax Act. The Karnataka High Court rejected the Revenue's reliance on a circular excluding writ matters from the monetary limit policy, holding that the Department could not use the absence of an alternative appeal remedy to bypass the threshold. The appeal was not entertained on merits and was dismissed, leaving the impugned order undisturbed.

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Issues: Whether the appeal was liable to be entertained despite the tax effect being below the monetary limit and whether the departmental circular could be invoked to sustain the appeal in a writ matter.

Analysis: The tax effect in the appeal was found to be less than Rs. 2 lakhs. The Court held that the departmental contention based on the circular excluding writ matters from monetary limits could not be accepted, because the assessee had approached the writ jurisdiction only in the absence of an alternative statutory remedy under the Income-tax Act. The Court reasoned that the Revenue could not derive an advantage from the absence of an alternative appeal remedy to avoid the monetary limit policy.

Conclusion: The appeal was not entertained on merits and was dismissed.

Final Conclusion: The dismissal was founded on the low tax effect and the inapplicability of the Revenue's objection to the writ context, leaving the impugned order undisturbed.

Ratio Decidendi: Where the tax effect is below the prescribed monetary threshold, a departmental appeal will not be entertained merely because the matter arose in writ jurisdiction and the assessee had no alternative statutory remedy.

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