Measures for reducing litigation- Clarification on Circulars 21/2015 and 8/2016

Appeal filing criteria: contest adverse tax judgments on merits, avoid mechanical appeals and withdraw violative filings.

Appeals and SLPs should generally not be filed where the tax effect is below prescribed monetary thresholds, and an appeal must not be filed merely because the tax effect exceeds those thresholds. Paragraph 8 identifies limited categories - constitutional validity challenges, findings that Board instruments are illegal or ultra vires, accepted Revenue Audit objections, and additions for undisclosed foreign assets - where adverse judgments should be contested on merits; this direction is intended to prevent mechanical filing, and appeals filed in violation may be withdrawn.