CBDT low-tax-effect limits govern pending appeals; later circular exceptions cannot revive an earlier filed appeal.

Applicable CBDT monetary limits govern pending appeals, and the low-tax-effect threshold can require disposal of an appeal even where the Revenue seeks to rely on a later exception. Exceptions introduced by a subsequent circular operate prospectively and cannot be used to sustain an appeal already filed before the exception came into force. As the appeal was filed in 2015 and the exception relied on was introduced only in 2024, the later exception did not justify continuation of the appeal, and disposal on the basis of low tax effect was upheld.

---

---

Issues: Whether the appeal was liable to be disposed of on account of low tax effect under the applicable CBDT circular, and whether the revenue could invoke an exception introduced after the appeal was filed.

Analysis: The applicable monetary limits under the later CBDT circular govern pending appeals. The exceptions carved out by the circulars operate prospectively and cannot be relied upon for an appeal already filed before the exception came into force. Since the appeal was filed in 2015 and the exception relied upon by the revenue was introduced only in 2024, the exception could not justify continuation of the appeal.

Conclusion: The appeal was rightly disposed of because the tax effect was below the prescribed monetary limit, and the revenue's reliance on the later exception was rejected.

---