TaxTMI 
TaxTMI 
Threshold set for monetary limits in filing appeals by Revenue: A policy shift towards reducing litigation and financial burden on the judiciary and taxpayers
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....section of administrative instructions and statutory provisions in the realm of tax litigation presents a complex matrix for legal interpretation and policy formulation. A deep dive into a particular High Court appeal concerning the Assessment Year 1993-94, revolving around the application of the Central Board of Direct Taxes (CBDT) Instruction No.3 of 2011, offers a fertile ground for examining t....
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....eriodic revisions reflect a policy shift towards reducing litigation and financial burden on the judiciary and taxpayers. * National Litigation Policy (2009): A crucial backdrop, emphasizing efficient litigation practices and aiming to cut down on unnecessary legal disputes involving the government. Detailed Judicial Interpretation and Application * Interpreting CBDT Instructions: Courts ....
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....ase * Statutory Nature of CBDT Instructions: The Court viewed these instructions as an extension of the statutory framework, thereby making them binding on the Revenue Department. This interpretation places administrative instructions on a quasi-legislative pedestal, enhancing their legal gravitas. * Harmonious Construction of Tax Provisions: The Court's effort to interpret Section 260....
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....ing appeals in low-stake cases, courts can allocate resources more effectively to more substantial and complex legal disputes. * Taxpayer Relief: Such interpretations provide relief to taxpayers, especially in cases where the cost of litigation might outweigh the tax effect. * Potential for Legislative Clarification: Given the divergent interpretations, there is a scope for legislative int....