Tax effect monetary limits apply to pending appeals, and later CBDT exceptions do not operate retrospectively.

The Bombay HC stated that the monetary limit for maintainability applied to pending appeals, and an appeal with tax effect below the prescribed threshold was liable to be disposed of on that basis. It further held that the CBDT letter dated 20 August 2018, which introduced exceptions, operated prospectively from the date of issuance and could not be applied retrospectively to appeals already filed before then. The appeal was therefore disposed of as not maintainable on account of low tax effect, while the question of law was left open.

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Issues: Whether the appeal was liable to be disposed of on the ground that the tax effect was below the prescribed monetary limit, and whether the exceptions introduced by the CBDT letter dated 20 August 2018 could be applied retrospectively to pending appeals.

Analysis: The appeal was instituted before 20 August 2018. The later CBDT modification creating exceptions was held to operate from the date of issuance and not retrospectively. The monetary limit for maintainability applied to pending appeals, but the newly introduced exceptions could not be invoked for appeals already filed before that date.

Conclusion: The appeal was disposed of as not maintainable on account of the low tax effect, and the question of law was left open.

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