CBDT monetary-limit circular applies to pending Revenue appeals, requiring withdrawal of low tax effect matters.

An enhanced CBDT monetary-limit circular for departmental appeals was treated as a continuation of the existing litigation policy and applied to appeals already pending on the date of issuance. Low tax effect Revenue appeals below the prescribed threshold were therefore not maintainable and had to be withdrawn or not pressed. The Tribunal also preserved the Revenue's liberty to seek recall where an appeal was wrongly included in the policy or fell within a recognised exception.

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Issues: Whether the Revenue appeals were liable to be dismissed in view of the enhanced monetary limit prescribed in the CBDT circular, and whether that circular applied to appeals pending on the date of its issuance.

Analysis: The monetary limit for departmental appeals was enhanced to Rs. 50,00,000 before the Tribunal, and the existing litigation policy governing withdrawal or non-pursuit of low tax effect matters remained in force. The amendment was treated as a continuation of the earlier circular policy and not as a stand-alone departure from it. The relaxation was therefore held applicable not only to future filings but also to appeals already pending for disposal. Liberty was reserved to the Revenue to seek recall if any appeal was wrongly included or fell within a prescribed exception.

Conclusion: The circular applied to pending appeals, and the Revenue appeals below the threshold were not maintainable and had to be dismissed as withdrawn.

Final Conclusion: The decision gives effect to the CBDT's enhanced monetary-limit policy by terminating low tax effect Revenue appeals, while preserving a limited remedy for mistakenly included or exceptional cases.

Ratio Decidendi: A beneficial CBDT circular enhancing monetary limits for departmental appeals applies to pending appeals as well as future filings, and appeals below the prescribed threshold are to be withdrawn or not pressed.

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