Low tax effect threshold barred departmental appeal; CBDT exception for external law enforcement information did not apply.

The departmental appeal was not maintainable because the tax effect was below the revised monetary limit prescribed by the CBDT circular, which was binding on the Revenue. The exception for additions based on information from external law enforcement agencies did not apply because information from the Income-tax Investigation Wing was not treated as information from an external law enforcement agency. The appeal was therefore barred by the low tax effect threshold.

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Issues: Whether the Department's appeal was maintainable in view of the revised monetary limit under the CBDT circular and whether the matter fell within the exception for cases based on information from external law enforcement agencies.

Analysis: The tax effect in the appeal was below the revised monetary limit for filing departmental appeals before the Tribunal. The applicable CBDT circular enhanced the monetary limit and made it binding on the Revenue. The exception relating to additions based on information from external law enforcement agencies did not apply because information from the Investigation Wing of the Income-tax Department was not information from an external law enforcement agency within the meaning of the exception.

Conclusion: The appeal was not maintainable on account of low tax effect and the exception was not attracted.

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