CBDT monetary-limit instructions bind the Revenue, barring low tax-effect departmental proceedings below the prescribed threshold.

A CBDT monetary-limit instruction was held binding on the Revenue, and departmental proceedings could not be pursued where the tax effect in each matter was below the prescribed threshold. The Tribunal applied the circular governing low-tax-effect cases and held that the Revenue could not maintain proceedings contrary to that instruction. As the appeals were filed in breach of the monetary-limit regime, they were treated as not maintainable and rejected at the threshold.

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Issues: Whether the Revenue's appeals were maintainable when the tax effect in each appeal was below the monetary limit prescribed by the CBDT circular and whether such circular was binding on the Revenue.

Analysis: The CBDT had issued successive instructions prescribing monetary limits for departmental appeals, including Instruction No. 1979 dated 27 March 2000, which fixed a limit of Rs. 1,00,000 for appeals before the Tribunal. The Tribunal held that the Revenue was bound by the circular and could not file appeals contrary to it. Relying on the binding nature of CBDT instructions and the principle that the Revenue cannot advance or maintain proceedings contrary to such circulars, the Tribunal concluded that the appeals had been filed in violation of the monetary-limit instruction.

Conclusion: The Revenue's appeals were not maintainable and were dismissed in limine.

Final Conclusion: The low tax effect and the binding CBDT instruction prevented the Revenue from pursuing the appeals, resulting in dismissal at the threshold.

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