CBDT monetary-limit circular barred low-tax-effect appeals and applied to pending cases, making the Revenue's appeals non-maintainable.

CBDT Circular No. 17/2019 enhanced the monetary limit for departmental appeals and applied that limit to pending appeals as well. Where the tax effect fell below the prescribed threshold, the Revenue could not continue the appeals and they were liable to be withdrawn or not pressed. A limited liberty was preserved for the Revenue to seek recall if a case had been wrongly included or fell within an exception. The appeals were therefore treated as non-maintainable under the applicable litigation policy.

---

---

Issues: Whether the Revenue's appeals were maintainable in view of the CBDT circular enhancing the monetary limit for filing appeals and applying it to pending appeals.

Analysis: The appeals involved tax effect below the enhanced monetary limit prescribed by Circular No. 17/2019, which amended the earlier litigation-management circular and expressly applied to pending appeals. The circular directed that pending appeals below the specified limit may be withdrawn or not pressed. Following the binding administrative policy and the approach approved in the cited Supreme Court order, the appeals could not be pursued further. Liberty was reserved to the Revenue to seek recall in cases wrongly included or falling within exceptions.

Conclusion: The appeals were non-maintainable and liable to be dismissed in favour of the assessee.

Final Conclusion: The Revenue's appeals failed on the ground of low tax effect under the applicable CBDT litigation policy, with only a limited liberty preserved for correction of cases wrongly included.

Ratio Decidendi: CBDT monetary-limit circulars governing filing and continuation of appeals apply to pending appeals and render appeals below the prescribed tax-effect threshold non-maintainable.

---