CBDT monetary limit for departmental appeals governs maintainability, leading to dismissal where tax effect is below threshold.

Departmental appeals before the ITAT are non-maintainable where the tax effect falls below the monetary limit prescribed by the applicable CBDT circulars. The enhanced limits under Circular No. 3/2018, as substituted by the circular dated 08.08.2019, apply to pending appeals as well, so the Revenue's appeal was dismissed for falling below the threshold. A reservation of liberty to seek revival in cases covered by exceptions or incorrect computation of tax effect did not affect the maintainability finding.

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Issues: Whether the Revenue appeal was maintainable in view of the CBDT circulars prescribing monetary limits for filing departmental appeals.

Analysis: The appeal involved tax effect below the threshold prescribed by the CBDT's circular issued on 08.08.2019, which operated in conjunction with Circular No. 3/2018 and substituted the relevant monetary-limit paragraphs. The decision relied on the settled policy that pending appeals of the Department are also governed by the enhanced monetary limits, and the appeal was treated as falling within that policy. The request that liberty be reserved to seek revival in cases covered by exceptions or involving incorrect computation of tax effect was accepted, but it did not alter the threshold-based maintainability analysis.

Conclusion: The Revenue appeal was held to be non-maintainable and was dismissed.

Final Conclusion: Departmental appeals below the prescribed tax-effect limit cannot be pursued before the Tribunal under the applicable CBDT policy, and such appeals are liable to be dismissed.

Ratio Decidendi: Where the tax effect in a departmental appeal falls below the monetary limit prescribed by the applicable CBDT circulars, the appeal is non-maintainable and must be dismissed.

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