2025 (2) TMI 770

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....the parties. 2. Learned counsel for the assessees submit that the tax effect in these appeals is less than Rs. 50,00,000/-. They point out that these tax appeals were instituted before 28 August 2018 and, therefore, should be dismissed based, inter alia, on circulars dated 10 December 2015 and 11 July 2018. 3. Learned counsel for the respondent-Revenue, however, contest the above submission. They pointed out that when these appeals were instituted, the tax effect was beyond the monetary limits specified in Circular No. 21 of 2015 dated 10 December 2015. They submitted that even circular No. 3 of 2018 dated 11 July 2018 was modified/amended on 20 August 2018. 4. Mr Sharma contended that on a conjoint reading of the circular dated 11 July ....

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....ed that these appeals do not fall within these exceptions. 9. Circular No. 3 of 2018 dated 11 July 2018 increased the monetary limits to Rs. 50,00,000/-. The exceptions were set out in paragraph 10. Again, it is not Revenue's case that these appeals fell within exceptions set out in paragraph 10 of the circular dated 11 July 2018. 10. Paragraph 13 of the circular dated 11 July 2108 is significant and is transcribed below for the convenience of reference:- "13. This Circular will apply to SLPs/appeals/ cross objections/ references to be filed henceforth in SC/HCs/ Tribunal and it shall also apply retrospectively to pending SLPs/ appeals/ cross objections/ references. Pending appeals below the specified tax limits in para 3 above may be w....