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Monetary-limit compliance governs departmental GST appeals even where the Commissioner authorises an application under Section 112(3). Appeals below the prescribed threshold require the Revenue to specifically plead and establish a recognised exception under the applicable litigation-control framework. A bare assertion of the Commissioner's permission does not prove a residual exception without material demonstrating a case-specific recorded opinion. Maintainability must be determined before the underlying tax merits are considered. Where no recognised exception is established, a below-threshold departmental appeal is liable to dismissal at the admission stage, leaving the substantive tax dispute undecided.
Monetary-limit compliance governs departmental GST appeals even where the Commissioner authorises an application under Section 112(3). Appeals below the prescribed threshold require the Revenue to specifically plead and establish a recognised exception under the applicable litigation-control framework. A bare assertion of the Commissioner's permission does not prove a residual exception without material demonstrating a case-specific recorded opinion. Maintainability must be determined before the underlying tax merits are considered. Where no recognised exception is established, a below-threshold departmental appeal is liable to dismissal at the admission stage, leaving the substantive tax dispute undecided.
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