Tax-effect based appeal limits bind the Revenue; appeals below the CBDT threshold are not maintainable.

CBDT instructions on departmental appeals used tax effect as the governing criterion for monetary limits, and the later instruction dated 27-3-2000 expressly superseded earlier directions by restricting appeals to cases above the prescribed threshold. The circulars and instructions were binding on the Revenue, so an appeal filed in breach of those limits could not be entertained. The text also notes judicial authority confirming that the Revenue cannot take a stand inconsistent with its own binding circulars. On that basis, appeals with tax effect below the prescribed monetary limit were treated as not maintainable.

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Issues: Whether the Revenue's appeals were maintainable when the tax effect was below the monetary limit prescribed by the CBDT circulars and instructions.

Analysis: The applicable CBDT instructions consistently used the concept of tax effect while prescribing monetary limits for departmental appeals. The later instruction of 27-3-2000 expressly superseded earlier instructions and limited appeals to cases where the tax effect exceeded the prescribed threshold. The circulars and instructions issued by the Board were binding on the Revenue, and an appeal filed in disregard of those limits could not be entertained. The decision also relied on judicial authority recognising that the Revenue cannot take a stand contrary to its binding circulars.

Conclusion: The Revenue's appeals were held to be not maintainable because the tax effect was below the prescribed monetary limit.

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