Prospective exceptions to appeal thresholds cannot revive earlier low-tax-effect Revenue appeals, requiring disposal in the assessee's favour.

Exceptions to monetary-threshold limits for Revenue appeals apply prospectively from their introduction, while revised monetary limits extend to pending appeals. An appeal instituted before the asserted exceptions were introduced could not rely on them where its tax effect remained below the applicable threshold. The appeal was therefore liable to be disposed of for low tax effect, in favour of the assessee.

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Issues: Whether the Revenue appeal, involving tax effect below the prescribed monetary threshold, was covered by exceptions introduced under earlier CBDT circulars.

Analysis: The exceptions introduced by the relevant circular apply prospectively from their introduction, whereas revised monetary limits apply to pending appeals. Since the appeal had been instituted before introduction of the asserted exceptions and its tax effect was below the applicable threshold, those exceptions did not apply.

Conclusion: The appeal was liable to be disposed of on account of low tax effect, in favour of the assessee.

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