Low tax effect circular barred the Revenue's appeal, and the assessee's cross objection fell away as infructuous.

Low tax effect limits barred the Revenue's appeal because Circular No. 17/2019, read with the earlier CBDT policy, applies to pending appeals as well as future appeals where the retrospective clause remains intact. The Tribunal held that the later circular only enhanced monetary thresholds and substituted the relevant paragraphs without displacing the existing rule on pending matters, so the departmental appeal was not maintainable. The assessee's cross objection, filed only in support of the impugned order, ceased to survive once the Revenue's appeal was held not maintainable and was therefore dismissed as infructuous.

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Issues: Whether the Revenue's appeal was not maintainable in view of the CBDT's low tax effect circular, and whether the assessee's cross objection became infructuous.

Analysis: The appeal involved tax effect below the monetary limit prescribed for departmental appeals. The Tribunal held that Circular No. 17/2019, read with the earlier circular governing low tax effect appeals, applies to pending appeals as well as future appeals, since the later circular only enhanced the monetary limits and substituted the relevant paragraphs of the earlier policy while leaving the clause applying the policy retrospectively to pending matters intact. The Tribunal also noted that the assessee's cross objection arose only as a support to the impugned appellate order and did not survive once the Revenue's appeal was not maintainable.

Conclusion: The Revenue's appeal was dismissed for low tax effect, and the cross objection was dismissed as infructuous.

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