Low tax effect bar prevented Revenue appeal; CBIC monetary limit made the matter not entertainable.

The Revenue's appeal was held not entertainable because the tax effect was below the CBIC circular's monetary limit of Rs. 50 lakhs for pursuing such matters. The tax effect was Rs. 23.96 lakhs, and no stated exception to the circular applied. The appeal was therefore dismissed on the ground of low tax effect, leaving the substantial questions of law open.

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Issues: (i) Whether the Revenue's appeal was liable to be entertained where the tax effect was below the monetary limit prescribed in the CBIC circular.

Issue (i): Whether the Revenue's appeal was liable to be entertained where the tax effect was below the monetary limit prescribed in the CBIC circular.

Analysis: The tax effect in the appeal was Rs. 23.96 lakhs, which was below the threshold of Rs. 50 lakhs fixed by the CBIC circular dated 11 July 2018 for pursuing such appeals. The case did not fall within any stated exception to that circular, and the appeal was covered by the policy against filing or pursuing low tax effect matters.

Conclusion: The appeal was not entertainable and was dismissed on the ground of low tax effect.

Final Conclusion: The Revenue could not pursue the appeal because the monetary limit barred its maintainability, leaving the substantial questions of law open.

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