CBDT monetary limit for Revenue appeals applies to pending cases, making low tax-effect appeals non-maintainable.

CBDT's enhanced monetary limit circular applied to pending Revenue appeals before the Tribunal, and appeals below the prescribed tax-effect threshold were not to be pursued. The note states that the earlier circular, read with the later revision, permitted withdrawal or non-pressing of such matters, so an appeal with tax effect below the threshold was treated as non-maintainable and liable to dismissal in favour of the assessee.

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Issues: Whether the Revenue appeal was maintainable in view of the CBDT's enhanced monetary limit circular and the fact that the tax effect was below the prescribed threshold.

Analysis: The appeal involved tax effect below Rs. 50,00,000. The applicable CBDT circular enhanced the monetary limit for appeals before the Tribunal and stated that the revised limit would apply to pending appeals as well. The earlier circular, as retained and read with the later circular, permitted withdrawal or non-pressing of pending appeals below the threshold. The appeal therefore fell within the category of matters not to be pursued by the Revenue.

Conclusion: The appeal was non-maintainable and liable to be dismissed. This conclusion is in favour of the assessee.

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