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HC determined that revenue appeals below monetary threshold of Rs. 2 crores must be withdrawn per CBDT circulars, rejecting argument for selective application. Court held that withdrawal provisions in circulars explicitly apply to pending appeals, while exceptions for filing new appeals below monetary limits are prospective from March 15, 2024. Following precedents in Anonymous v. Anonymous and related cases, HC disposed of appeals as revenue counsel lacked instructions to withdraw, despite clear directive in circulars. Court emphasized holistic interpretation of circulars, confirming retrospective application for withdrawal of pending matters while maintaining prospective application for new filings.
HC determined that revenue appeals below monetary threshold of Rs. 2 crores must be withdrawn per CBDT circulars, rejecting argument for selective application. Court held that withdrawal provisions in circulars explicitly apply to pending appeals, while exceptions for filing new appeals below monetary limits are prospective from March 15, 2024. Following precedents in Anonymous v. Anonymous and related cases, HC disposed of appeals as revenue counsel lacked instructions to withdraw, despite clear directive in circulars. Court emphasized holistic interpretation of circulars, confirming retrospective application for withdrawal of pending matters while maintaining prospective application for new filings.
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