Low tax effect threshold bars merits review and leads to dismissal under litigation policy

Where the tax effect in the disputed matter fell below the monetary threshold prescribed by the applicable litigation policy, the Supreme Court dismissed the appeals without examining the merits. The Court treated the Board's instruction as controlling for maintainability in such low-tax-effect matters and declined further adjudication. The connected proceedings were therefore concluded on the basis of the prescribed tax-effect threshold.

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Issues: Whether the appeals were liable to be dismissed in view of the low tax effect and the litigation policy embodied in the Board's instruction.

Analysis: The appeals were examined in the light of the respondent's application for dismissal and the Court noted that the tax effect of the subject matter was below the threshold prescribed under the applicable litigation policy instruction issued by the Board. In such circumstances, no further adjudication on the merits of the appeals was undertaken.

Conclusion: The appeals were dismissed as falling below the prescribed tax-effect threshold.

Final Conclusion: The challenge was not entertained further and the connected proceedings stood concluded on the basis of the low-tax-effect policy.

Ratio Decidendi: Where the tax effect falls below the monetary threshold prescribed by the applicable litigation policy instruction, the appeal is liable to be dismissed without merits adjudication.

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