Low-tax-effect exception requires the appeal to arise from the audit-accepted proceedings, not a different section 154 rectification matter.

An accepted revenue audit objection does not automatically bring an appeal within the low-tax-effect exception under CBDT instruction clause 10(c); the exception applies only where the impugned appeal arises from the proceedings in which the audit objection was accepted. Here, the audit objection related to reassessment under section 147, while the appeal before the ITAT concerned rectification under section 154. Because the appeal did not stem from the audit-accepted proceedings, the miscellaneous application seeking recall of the earlier low-tax-effect dismissal was found unsustainable and dismissed.

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Issues: Whether the Revenue's miscellaneous application seeking recall of the earlier order dismissing its appeal for low tax effect was maintainable on the ground that the case fell within the exception relating to accepted revenue audit objection.

Analysis: The relevant audit objection pertained to the reassessment made under section 147 of the Income-tax Act, 1961, whereas the appeal before the Tribunal arose from rectification proceedings under section 154 of the Income-tax Act, 1961. Since the impugned appeal did not arise from proceedings in which the audit objection had been accepted, the case did not satisfy the exception carved out in clause 10(c) of the applicable CBDT instruction dealing with appeals below the monetary threshold.

Conclusion: The Revenue's miscellaneous application was held to be without merit and was dismissed.

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