Departmental appeals disputing only a penalty are governed by...

Departmental appeals disputing only a penalty are governed by the disputed penalty for monetary-limit purposes. Where the amount is below the prescribed limit, the Revenue must specifically identify and establish a recognised exception. Reliance on a residual exception requires material that the Commissioner considered the particular matter and recorded the requisite opinion; bare approval or authorisation to appeal is insufficient. Maintainability must be determined before merits, resulting in threshold dismissal where policy compliance is not shown.