TaxTMI 
TaxTMI 
2026 (7) TMI 816
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....sani. P. C. 1. The above Appeal has been placed on board for directions today because we find that the tax effect in the Appeal is less than Rs. 2 Crores as stated in the CBDT Circular No. 9 of 2024 dated 17th September, 2024. 2. Mr. Suresh Kumar, the learned Advocate appearing on behalf of the Revenue, submitted that the present Appeal is lodged on 16th June, 2023, and on that date it wa....
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.... 4. According to Mr. Jasani, the reliance on the exception is wholly misplaced as the same pertains only to litigation arising out of disputes in TDS/TCS matters, in both domestic and international taxation charges. In the facts of the present case, the Appeal does not relate to any TDS/TCS matter in any domestic or international taxation charge. Hence, the reliance placed on the above exception i....
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....ll, the exceptions.carved.out.by the CBDT Circulars would apply only prospectively i.e. from the date of the introduction of such exception. 8. Admittedly, before 20 August 2018, these appeals were not covered by any exceptions. However, these appeals were filed because they were beyond the monetary limits prescribe then. The monetary limits have now been revised. These revised monetary l....
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.... only prospectively, and would have no application if they were introduced after the filing of the Appeal. Admittedly, in the present case, the Appeal was lodged on 16th June, 2023, while the exception the Revenue relies upon was introduced vide Circular dated 15th March, 2024. Hence, the exception relied upon by the Revenue in the Circular dated 15th March, 2024 cannot be a justification for pros....