CBDT monetary limit for revenue appeals applied strictly; exception rejected and the appeal dismissed.

Revenue appeals below the monetary threshold in CBDT Circular No. 3 of 2018 are not maintainable unless a recognised exception applies. The High Court applied the circular on its own terms and held that a tax effect of Rs. 24,00,519 fell below the prescribed limit. The proposed exception was rejected because a broad reading would allow the Department to invoke exceptions in every case and undermine the circular's object. The appeal was therefore treated as not maintainable and dismissed.

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Issues: Whether the revenue appeal was maintainable in view of Circular No. 3 of 2018 dated 11.07.2018, where the tax effect was below the prescribed monetary limit, and whether the case fell within any exception to the circular.

Analysis: The appeal was barred by the CBDT circular because the tax effect was only Rs. 24,00,519/-, which was below the threshold. The asserted exception was not accepted, since accepting such a plea would undermine the circular by permitting the Department to invoke exceptions in every case. The circular was therefore applied according to its own terms.

Conclusion: The appeal was held to be not maintainable and was dismissed.

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