CBDT tax-effect limit bars revenue appeals unless a recognised exception applies; Tribunal dismissal sustained.

Revenue appeals were treated as not maintainable where the tax effect in each assessment year fell below the CBDT monetary limit, and the Tribunal's dismissal was sustained because no recognised exception was shown. The recognised exceptions noted were cases involving an accepted revenue audit objection, challenge to a Board order, notification, instruction or circular, contemplated prosecution, or a question on constitutional validity. On the facts stated, the Revenue did not bring the matter within any exception, so no question of law arose and no interference with the Tribunal's order was warranted.

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Issues: Whether the Revenue's appeals were liable to be dismissed in limine on the ground that the tax effect was below the monetary limit prescribed by the Central Board of Direct Taxes circular and none of the recognised exceptions applied.

Analysis: The Tribunal had dismissed the appeals because the tax effect in each assessment year was below Rs. 1,00,000, relying on the Board's instructions governing departmental appeals. The Court noted that the same approach had been recognised earlier, and that appeals could still be pursued despite the monetary limit only in specified exceptional situations, namely where a revenue audit objection had been accepted, where a Board order, notification, instruction or circular was under challenge, where prosecution was contemplated, or where constitutional validity was questioned. The Revenue did not show that the case fell within any of those exceptions.

Conclusion: The dismissal of the Revenue's appeals by the Tribunal was upheld, as no question of law arose and the Tribunal's order called for no interference.

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