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AI Drafter

Generate professional replies to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.

Step 1 – Issue Identification & Review

The AI analyses your query, notice, order, or uploaded documents and identifies the key issues involved.

• Review the issues identified by the AI
• Add, edit, remove, or refine issues as required


Step 2 – Draft Generation

Once you approve the issues, the AI performs issue-wise legal research and prepares a structured draft response.

• Relevant statutory provisions
• Judicial precedents and Supreme Court, High Court and other citations
• Issue-wise legal analysis
• Practical arguments and supporting content
• Professionally structured draft ready for further review.

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        Case ID :

        2019 (10) TMI 484 - AT - Income Tax

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        CBDT monetary limit bars departmental appeal before ITAT when tax effect is below the prescribed threshold. Departmental appeals before the ITAT are not maintainable where the tax effect falls below the CBDT's revised monetary limit under Circular No. 17 of ...
                        Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                          Provisions expressly mentioned in the judgment/order text.

                              CBDT monetary limit bars departmental appeal before ITAT when tax effect is below the prescribed threshold.

                              Departmental appeals before the ITAT are not maintainable where the tax effect falls below the CBDT's revised monetary limit under Circular No. 17 of 2019, subject to recognised exceptions. On the facts stated, the disputed tax effect was below the prescribed threshold, so the departmental appeal could not be entertained and was dismissed.




                              Issues: Whether the departmental appeal was maintainable in view of the CBDT monetary limit for filing appeals before the Income Tax Appellate Tribunal.

                              Analysis: The appeal was tested against the revised monetary limit prescribed by the CBDT through Circular No. 17 of 2019, which enhanced the limit for appeals before the Tribunal to Rs. 50,00,000. The tax effect in the present appeal was found to be below that threshold. In such circumstances, the departmental appeal was not maintainable, subject to the stated exceptions in the circular.

                              Conclusion: The appeal was held to be not maintainable on account of low tax effect and was dismissed.

                              Final Conclusion: The departmental challenge could not be entertained because the disputed tax effect did not cross the revised monetary threshold fixed for appeals before the Tribunal.

                              Ratio Decidendi: A departmental appeal is not maintainable where the tax effect is below the applicable monetary limit prescribed by the CBDT, unless the case falls within a recognised exception.


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                              ActsIncome Tax
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