CBDT monetary limits for tax appeals apply to pending matters, and later exceptions cannot revive earlier appeals.

Revised CBDT monetary limits apply to pending income tax appeals, and any later exception introduced by circular cannot be used retrospectively to preserve appeals filed before the exception came into force. Because the appeals were filed before 20 August 2018, the Revenue could not rely on the subsequent exception, and the assessee's objection to continuation of the appeals was accepted. The appeals were therefore treated as not maintainable under the revised tax-effect limits and disposed of accordingly.

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Issues: Whether the pending income tax appeals were liable to be disposed of on the basis of the revised CBDT monetary limits, and whether the exception relied upon by the Revenue could be applied retrospectively to save the appeals.

Analysis: The Court noted that the monetary limits prescribed by CBDT circulars apply to pending appeals, but any exception carved out by a later circular operates only prospectively from the date on which such exception is introduced. Since the appeals were filed before 20 August 2018, the Revenue could not invoke the later exception for those appeals. In view of the revised monetary limits and the tax effect involved, the assessee's objection to continuation of the appeals was accepted.

Conclusion: The appeals were not maintainable in view of the monetary limits and were disposed of in favour of the assessee.

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