Revised monetary limits govern pending tax appeals, while later exceptions operate prospectively and cannot sustain earlier-filed departmental appeals.

Revised monetary-limit circulars governing departmental income-tax appeals apply to pending appeals as well as fresh filings. Accordingly, where the tax effect falls below the revised threshold, the pending appeal cannot be continued. Exceptions introduced by a later circular operate prospectively from their date of introduction and cannot be invoked to sustain an appeal filed earlier. The factual question of whether the appeal fell within that later exception therefore remains unaddressed. The notes identify the resulting principle as requiring discontinuance of the appeal where the revised threshold is not met and the later exception is unavailable, while leaving underlying questions of law open for a suitable case.

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Issues: (i) Whether the revised monetary limits prescribed in CBDT Circular No. 9 of 2024 dated 17.09.2024 apply to pending income-tax appeals; (ii) Whether an exception introduced by CBDT Circular dated 15.03.2024 could be relied upon to continue an appeal that had been filed before the introduction of that exception.

Issue (i): Whether the revised monetary limits prescribed in CBDT Circular No. 9 of 2024 dated 17.09.2024 apply to pending income-tax appeals.

Analysis: The applicable legal framework was the CBDT policy governing monetary limits for departmental appeals. The binding position followed was that revised monetary-limit circulars apply not only to fresh appeals but also to pending appeals. Since the tax effect in the present appeal was below Rs. 2 crores under the circular dated 17.09.2024, the pending appeal became governed by that revised threshold.

Conclusion: The revised monetary limits under CBDT Circular No. 9 of 2024 dated 17.09.2024 apply to pending appeals; this issue was decided in favour of the assessee.

Issue (ii): Whether an exception introduced by CBDT Circular dated 15.03.2024 could be relied upon to continue an appeal that had been filed before the introduction of that exception.

Analysis: The legal framework considered was the operation of exceptions carved out in CBDT circulars. The governing principle applied was that such exceptions operate prospectively from the date of their introduction and do not validate prosecution of appeals already filed before that date. As the appeal had been lodged on 16.06.2023 and the relied-upon exception was introduced only on 15.03.2024, that exception was unavailable for sustaining the appeal. The further contention on whether the case factually fell within the exception was left open and was not adjudicated.

Conclusion: The exception introduced by the CBDT Circular dated 15.03.2024 could not be invoked for an appeal filed earlier; this issue was decided in favour of the assessee.

Final Conclusion: The appeal could not be continued once the revised monetary-limit circular rendered the tax effect insufficient and the later-introduced exception was inapplicable to the already-filed appeal; the revenue's questions of law were left open for consideration in an appropriate case.

Ratio Decidendi: Revised CBDT monetary-limit circulars govern pending departmental appeals, but exceptions introduced by later circulars operate only prospectively and cannot be applied to appeals instituted before the date of such exception.

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