CBDT monetary-limit circulars apply to pending appeals; later exceptions cannot revive an earlier-filed Revenue appeal.

CBDT monetary-limit circulars apply to pending appeals, so an appeal with tax effect below the prescribed threshold cannot be entertained unless a valid exception applies. A later circular introducing an exception operates prospectively and cannot be used to sustain an appeal filed before that exception came into force. As the Revenue's appeal was filed before the exception was introduced, the exception was unavailable, and the appeal was disposed of on the basis of the monetary limit, with the questions of law left open for an appropriate case.

---

---

Issues: Whether the appeal could be entertained despite the tax effect being below the monetary limit prescribed in CBDT Circular No. 09 of 2024 dated 17th September 2024, and whether the Revenue could rely on an exception introduced by a later circular to continue a pending appeal.

Analysis: The monetary limits contained in the CBDT circular apply to pending appeals as well. The exceptions carved out by subsequent circulars operate prospectively and cannot justify prosecuting an appeal filed before the exception was introduced. Since the appeal was filed in May 2022 and the exception relied upon by the Revenue was introduced only later, the exception was unavailable for sustaining the appeal.

Conclusion: The appeal could not be entertained and was liable to be disposed of on the basis of the monetary limit.

Final Conclusion: The Revenue's appeal was not proceeded with because the tax effect fell below the applicable monetary threshold, while the questions of law were left open for an appropriate case.

Ratio Decidendi: CBDT monetary-limit circulars apply to pending appeals, but exceptions introduced by later circulars operate only prospectively and cannot revive or sustain earlier-filed appeals.

---