Section 158BD notice requirements and revised low-tax-effect threshold lead to disposal of appeals, with questions of law left open.

Section 158BD requires the statutory preconditions for issuing a notice to be satisfied before the notice can be sustained, and the Gujarat High Court view cited in the text is that a notice issued under Section 158BD read with Section 158BC cannot stand where those requirements are not met. The text also notes that, under the CBDT circular dated 17 September 2024, the monetary threshold for filing an appeal to the Supreme Court was raised from two crores to five crores. Since the stated tax effect in the appeals was below that limit, the appeals were disposed of, and all questions of law were left open.

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Outcome: The appeals were disposed of after noting that the tax effect was below the revised monetary threshold for filing appeals before the Supreme Court, and the questions of law were left open.

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