CBDT monetary limit bars low-tax-effect Revenue appeals, and the limit applies to pending matters as well.

A Revenue appeal with tax effect below the CBDT-prescribed monetary limit was held to be not maintainable and dismissed. CBDT Circular No. 17/2019, issued as an enhancement of the existing policy under Circular No. 3/2018, was applied to pending appeals as well. The Tribunal followed the settled position that such appeals should not be pressed unless they fall within recognised exceptions. It also noted that the Department may seek appropriate remedial steps where a case was wrongly included because of incorrect tax-effect computation or where a permissible exception applies.

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

Analysis: The appeal related to a relief granted by the first appellate authority and the tax effect was below the monetary limit prescribed by CBDT Circular No. 17/2019, issued as an enhancement of the existing policy under Circular No. 3/2018. The circular was applied to pending appeals as well, and the Tribunal followed the settled position that appeals below the threshold are not to be pressed unless covered by recognised exceptions. The Tribunal also accepted that the Department could seek appropriate remedial steps if any case was wrongly included due to incorrect computation of tax effect or for any permissible exception.

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

Ratio Decidendi: A Revenue appeal involving tax effect below the CBDT-prescribed monetary limit is not maintainable and must be dismissed, and the monetary-limit circular applies to pending appeals as well.

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