Gujarat High Court Judgments — 2018

The High Court allowed the Revenue's appeals. The Court noted that the learned advocate for the Revenue pointed out legislative changes, specifically the deletion of Clause (xii) of Sub-Section (1) of Section 5 of the Wealth Tax Act, 1957, effective from 01.04.1993, by Act 18 of 1992. Consequently, the Tribunal's reliance on a Gujarat High Court judgment in the case of Shantadevi P. Gaekwad, which was rendered when Clause (xii) was in force (for Assessment Year 1972-73), was incorrect for the Assessment Years 2004-05 and onwards. The assessee's counsel conceded to the Revenue's contentions, acknowledging that the legislative changes were likely not brought to the Tribunal's notice. The impugned common judgment of the Tribunal in favor of the assessee was set aside, and the order of the Revenue authority was restored. All Tax Appeals were allowed.

The High Court allowed the appeals filed by the Revenue. The Court noted that the Tribunal had relied on a Gujarat High Court judgment in the case of Shantadevi P. Gaekwad Vs. Wealth-tax Officer [2017] 82 taxmann.com 460 (Gujarat). However, the Revenue pointed out that Section 5(1)(xii) of the Wealth Tax Act, 1957, under which the exemption was granted, was deleted effective from 01.04.1993 by Act 18 of 1992. The assessee's counsel conceded to this fact and agreed that the legislative changes were not brought to the Tribunal's notice. Consequently, the Tribunal's reliance on the earlier judgment, which was rendered when Section 5(1)(xii) was in force (for Assessment Year 1972-73), was erroneous for the Assessment Years 2004-05 onwards. The impugned common judgment of the Tribunal was set aside, and the order of the Revenue authority was restored. All Tax Appeals were allowed.

The High Court allowed the appeals filed by the Revenue. The Court noted that the Tribunal had relied on a Gujarat High Court judgment in the case of Shantadevi P. Gaekwad Vs. Wealth-tax Officer [2017] 82 taxmann.com 460 (Gujarat). However, the Revenue pointed out that Section 5(1)(xii) of the Wealth Tax Act, 1957, under which the exemption was granted, was deleted effective from 01.04.1993 by Act 18 of 1992. The assessee's counsel conceded to this fact and agreed that the legislative changes were not brought to the Tribunal's notice. Consequently, the Tribunal's reliance on the earlier judgment, which was rendered when Section 5(1)(xii) was in force (for Assessment Year 1972-73), was erroneous for the Assessment Years 2004-05 onwards. The impugned common judgment of the Tribunal was set aside, and the order of the Revenue authority was restored. All Tax Appeals were allowed.

The High Court held that the expenditure incurred by the assessee on the fertility improvement program was revenue in nature and not capital. While the lower authorities, including the ITAT, had focused on the allowability as business expenditure and concurred with the assessee, they had not explicitly addressed the capital versus revenue nature of the expenditure in detail. The Court, after examining the nature of the activities undertaken, found them to be general in nature, aimed at improving practices for better fertility amongst milk animals by addressing issues causing infertility. These activities included awareness programs, fertility camps, deworming, vaccination, and providing feed and mineral mixtures. The Court reasoned that these expenditures were for the purpose of the assessee's business and not co-relatable to any specific tangible returns that could be expected from capital expenditure. Therefore, there was no reason to believe the expenditure was capital in nature. The Tax Appeals were dismissed.

The High Court allowed the appeals filed by the Revenue. The Court noted that the Tribunal had relied on a Gujarat High Court judgment in the case of Shantadevi P. Gaekwad Vs. Wealth-tax Officer [2017] 82 taxmann.com 460 (Gujarat). However, the Revenue pointed out that Section 5(1)(xii) of the Wealth Tax Act, 1957, under which the exemption was granted, was deleted effective from 01.04.1993 by Act 18 of 1992. The assessee's counsel conceded to this fact and agreed that the legislative changes were not brought to the Tribunal's notice. Consequently, the Tribunal's reliance on the earlier judgment, which was rendered when Section 5(1)(xii) was in force (for Assessment Year 1972-73), was erroneous for the Assessment Years 2004-05 onwards. The impugned common judgment of the Tribunal was set aside, and the order of the Revenue authority was restored. All Tax Appeals were allowed.

The High Court held that the impugned notice for reopening the assessment was liable to be quashed. The Court found that the entire issue concerning the assessee's treatment of unutilized CENVAT credit in the valuation of closing stock had been subjected to minute scrutiny during the original assessment proceedings. The Assessing Officer had raised multiple queries, received replies from the assessee, and after such examination, passed the original assessment order, making limited additions. Therefore, the AO was not justified in re-examining the same issue, which amounted to a mere change of opinion, a ground that prevents reopening even after amendments to Section 147, as held in CIT vs. Kelvinator of India Limited. Furthermore, the Court noted that the notice was issued beyond a period of four years from the end of the relevant assessment year. Since there was no failure on the part of the assessee to disclose truly and fully all material facts, and the AO referred to material already on record, the notice was quashed on this ground as well. The petition was allowed, and the impugned notice was set aside.

The High Court dismissed the Revenue's appeals. The Court held that the Supreme Court's decision in Maxopp Investment Ltd. did not fundamentally alter the understanding of Section 14A and Rule 8D as previously interpreted by various courts. Specifically, the Court found that Maxopp Investment Ltd. did not lay down a proposition that the requirement of the Assessing Officer's satisfaction under sub-rule (1) of Rule 8D, before applying the formula in sub-rule (2), was dispensed with. The Court also noted that the Supreme Court's decision in Maxopp Investment Ltd. concerning the case of Avon Cycles Ltd. did not change the position where the High Court had found that the funds utilized were mixed funds and the interest paid was on investments made, leading to no substantial question of law. The High Court reiterated its previous stance that if an assessee can demonstrate the availability of surplus interest-free funds for making investments generating tax-free income, disallowance under Section 14A is not justified. The Court also referred to a previous judgment of the same High Court concerning the same assessee for the assessment year 2004-05, which had attained finality and held that disallowance was not permissible when sufficient surplus interest-free funds were available. Therefore, the appeals were dismissed.

The High Court held that while Section 11(2)(a) of the Income Tax Act, 1961, requires the furnishing of a statement specifying the purpose for which income is accumulated or set apart, any inaccuracy or lack of full declaration in the prescribed format would not necessarily be fatal. The prime requirement is the statement of the purpose. In this case, although the declaration in Form 10 might not have been fully sufficient, the assessee, when called upon by the Assessing Officer, provided a detailed explanation of the purpose through a board resolution. This resolution clearly set out the background and the specific purpose for which the funds were being set apart, namely, for ongoing hospital projects and modernization of existing hospitals. Therefore, the Court found no error in the Tribunal's view that the assessee had sufficiently stated the purpose. The appeals were dismissed.

The High Court dismissed the Revenue's appeals. The Court held that the Supreme Court's decision in Maxopp Investment Ltd. did not fundamentally alter the understanding of Section 14A and Rule 8D as previously interpreted by various courts. Specifically, the Court found that Maxopp Investment Ltd. did not lay down a proposition that the requirement of the Assessing Officer's satisfaction under sub-rule (1) of Rule 8D, before applying the formula in sub-rule (2), was dispensed with. The Court also noted that the Supreme Court's decision in Maxopp Investment Ltd. concerning the case of Avon Cycles Ltd. did not change the position where the High Court had found that the funds utilized were mixed funds and the interest paid was on investments made, leading to no substantial question of law. The High Court reiterated its previous stance that if an assessee can demonstrate the availability of surplus interest-free funds for making investments generating tax-free income, disallowance under Section 14A is not justified. The Court also referred to a previous judgment of the same High Court concerning the same assessee for the assessment year 2004-05, which had attained finality and held that disallowance was not permissible when sufficient surplus interest-free funds were available. Therefore, the appeals were dismissed.

The High Court held that while Section 11(2)(a) of the Income Tax Act, 1961, requires the furnishing of a statement specifying the purpose for which income is accumulated or set apart, any inaccuracy or lack of full declaration in the prescribed format would not necessarily be fatal. The prime requirement is the statement of the purpose. In this case, although the declaration in Form 10 might not have been fully sufficient, the assessee, when called upon by the Assessing Officer, provided a detailed explanation of the purpose through a board resolution. This resolution clearly set out the background and the specific purpose for which the funds were being set apart, namely, for ongoing hospital projects and modernization of existing hospitals. Therefore, the Court found no error in the Tribunal's view that the assessee had sufficiently stated the purpose. The appeals were dismissed.

The High Court noted that the Supreme Court's decision in Justice K.S. Puttaswami (Retd.) vs. Union of India directly addressed and upheld the government's right to insist on linking Aadhaar cards with income tax returns. Therefore, the issue raised by the petitioner was covered by the Supreme Court's judgment. However, the Court acknowledged that the petitioner had already filed their return under an interim order. The Court left it to the petitioner to argue the effect of filing such a return before the Assessing Authority and directed the Assessing Authority to judge the validity of the return, considering the Supreme Court's judgment. The petition was disposed of on this basis.

The High Court held that the impugned notice should be quashed solely on the ground that it was issued beyond a period of four years from the end of the relevant assessment year, and there was no suggestion on record of any failure on the part of the assessee to disclose truly and fully all material facts. Additionally, the Court commented that the issue of disproportionate bifurcation of expenditures between eligible and non-eligible units, cited as a reason for reopening, pertained to the assessee's claim for deduction under Section 10B. Since this claim was examined by the Assessing Officer during the original assessment proceedings, as noted in the previous judgment, it would not be open for him to re-examine it, even if on another aspect or element, through reassessment proceedings. The Court noted that the Assessing Officer had raised multiple queries regarding the claim during the original assessment, and the assessee had provided a detailed reply with supporting documents, including audit reports and unit-wise statements of income, which demonstrated the computation of profits and the allocation of expenses. The Court found that the assessee had complied with the conditions for claiming deduction under Section 10B.

The High Court dismissed the Tax Appeals. The Court observed that the Supreme Court's decision in Maxopp Investment Ltd. did not fundamentally alter the understanding of Section 14A and Rule 8D. Specifically, the Supreme Court's judgment did not negate the requirement for the Assessing Officer to be satisfied (as per sub-rule (1) of Rule 8D) before applying the formula in sub-rule (2). The Court reiterated that the applicability of Section 14A read with Rule 8D is not automatic merely because an assessee has mixed funds (interest-free and interest-bearing) and utilizes them for investments generating tax-free income. The Court noted that previous judgments of this High Court, including one concerning the same assessee for the assessment year 2008-09, had held that disallowance under Section 14A is not permissible if the assessee demonstrates sufficient surplus interest-free funds for making such investments. The Court found no error in the Tribunal's decision to restrict the disallowance, aligning with the principle that disallowance is not justified when sufficient interest-free funds are available.

The High Court held that the assessee's argument regarding the interpretation of the due date for depositing employee's contributions was incorrect. Section 36(1)(va) of the Income Tax Act requires that any sum received from employees, which is covered under Section 2(24)(x), would be disallowed if not credited to the employee's account in the relevant funds on or before the due date. The Explanation to Section 36(1)(va) defines 'due date' as the date by which the employer is required to credit the employee's contribution to the fund under any Act, rule, or order. Section 38(1) of the Employees' Provident Funds and Miscellaneous Provisions Act, 1952, mandates that the employer shall, before paying the member his wages, deduct the employee's contribution and pay it to the fund within fifteen days of the close of every month. The Court clarified that 'within fifteen days of the close of every month' refers to the month for which wages are paid and the corresponding liability to deduct and deposit arises, not the month in which the salary is actually disbursed if it's delayed. Therefore, the disallowance made by the AO and confirmed by the ITAT was upheld.

The High Court granted permission to the Revenue to withdraw the appeals. The reasoning provided is that the learned advocate for the department, under instructions, sought permission to withdraw the appeals because the tax effect involved in these appeals was below the minimum threshold limit provided by the CBDT in its circular dated 11.07.2018. This circular enables the department to prefer and maintain appeals before the High Court. The Court found this submission acceptable and accordingly disposed of the Tax Appeals.

The High Court granted permission to the Revenue to withdraw the appeals. The Court reasoned that the Revenue's request was based on a CBDT circular dated July 11, 2018, which sets a minimum threshold for the tax effect for preferring and maintaining appeals before the High Court. Since the tax effect in the present appeals was below this stipulated limit, the Revenue was permitted to withdraw them. Consequently, the Tax Appeals were disposed of accordingly. The judgment does not discuss any substantive legal issues related to the income tax assessment itself, as the appeals were withdrawn on procedural grounds related to the monetary limit for appeals.

The High Court granted permission to the Revenue to withdraw the appeals. The reasoning provided is that the learned advocate for the Revenue, under instructions from the department, sought permission to withdraw the appeals because the tax effect involved in these appeals was below the minimum threshold limit stipulated by the CBDT in its circular dated 11.07.2018. This circular enables the department to prefer and maintain appeals before the High Court. Consequently, the Tax Appeals were disposed of as withdrawn. No specific issue was decided on merits.

The High Court granted permission to the Revenue to withdraw the appeals. The reasoning provided is that the learned advocate for the Revenue, under instructions from the department, sought permission to withdraw the appeals because the tax effect involved in these appeals was below the minimum threshold limit stipulated by the CBDT in its circular dated 11.07.2018. This circular enables the department to prefer and maintain appeals before the High Court. Consequently, the Tax Appeals were disposed of as withdrawn. No specific issue was decided on merits.

The High Court granted the Revenue's request to withdraw the Tax Appeals. The Court noted that the learned advocate for the Revenue, under instructions from the department, sought permission to withdraw the appeals. The reason provided was that the tax effect involved in these appeals was below the minimum threshold limit prescribed by the CBDT in its circular dated 11.07.2018. This circular dictates the conditions under which the department can prefer and maintain appeals before the High Court. The Court found this reason sufficient and granted the permission. Consequently, the Tax Appeals were disposed of as withdrawn. The judgment does not address the merits of any underlying tax disputes.

The High Court of Gujarat granted permission to the Revenue to withdraw the tax appeals. The reasoning provided was that the tax effect in these appeals was below the minimum threshold limit specified in the CBDT circular dated July 11, 2018. This circular provides the criteria for the department to prefer and maintain appeals before the High Court. Since the condition of the tax effect was not met, the Court allowed the withdrawal. The ratio decidendi is that appeals filed by the Revenue, where the tax effect is below the prescribed threshold by a CBDT circular, can be withdrawn upon seeking permission from the Court. The operative direction was that the Tax Appeals are disposed of accordingly, implying they are dismissed as withdrawn.

The High Court granted permission to the Revenue to withdraw the appeals. The Court reasoned that the Revenue's request was based on a CBDT circular dated July 11, 2018, which sets a minimum threshold for the tax effect for preferring and maintaining appeals before the High Court. Since the tax effect in the present appeals was below this stipulated limit, the Revenue was permitted to withdraw them. Consequently, the Tax Appeals were disposed of accordingly. The judgment does not discuss any substantive legal issues related to the income tax assessment itself, as the appeals were withdrawn on procedural grounds related to the monetary limit for appeals.

The High Court granted permission to the Revenue to withdraw the appeals. The reasoning provided is that the learned advocate for the Revenue, under instructions from the department, sought permission to withdraw the appeals because the tax effect involved in these appeals was below the minimum threshold limit stipulated by the CBDT in its circular dated 11.07.2018. This circular enables the department to prefer and maintain appeals before the High Court. Consequently, the Tax Appeals were disposed of as withdrawn. No specific issue was decided on merits.

The High Court of Gujarat granted permission to the Revenue to withdraw the tax appeals. The reasoning provided was that the tax effect in these appeals was below the minimum threshold limit specified in the CBDT circular dated July 11, 2018. This circular provides the criteria for the department to prefer and maintain appeals before the High Court. Since the condition of the tax effect was not met, the Court allowed the withdrawal. The ratio decidendi is that appeals filed by the Revenue, where the tax effect is below the prescribed threshold by a CBDT circular, can be withdrawn upon seeking permission from the Court. The operative direction was that the Tax Appeals are disposed of accordingly, implying they are dismissed as withdrawn.

The High Court granted the Revenue's request to withdraw the appeals. The reasoning was based on the CBDT circular dated July 11, 2018, which allows the department to withdraw appeals if the tax effect is below the stipulated minimum threshold. The Court found this reason sufficient to permit the withdrawal. Therefore, all the listed Tax Appeals were disposed of as withdrawn. The operative direction was to dispose of the Tax Appeals accordingly. No specific issue was left undecided, as the appeals were withdrawn before any substantive decision on their merits.

The High Court granted permission to the Revenue to withdraw the appeals. The reasoning provided is that the learned advocate for the Revenue, under instructions from the department, sought permission to withdraw the appeals because the tax effect involved in these appeals was below the minimum threshold limit stipulated by the CBDT in its circular dated 11.07.2018. This circular enables the department to prefer and maintain appeals before the High Court. Consequently, the Tax Appeals were disposed of as withdrawn. No specific issue was decided on merits.

The High Court granted the Revenue's request to withdraw the appeals. The Court reasoned that the Revenue's decision to withdraw was based on the CBDT circular dated July 11, 2018, which sets a minimum tax effect threshold for preferring and maintaining appeals before the High Court. Since the tax effect in these appeals was below this threshold, the department was entitled to withdraw them. The Court accordingly disposed of the Tax Appeals as withdrawn. No specific findings were made on the merits of any of the underlying tax disputes.

The High Court granted the Revenue's request to withdraw the appeals. The reasoning was based on the explicit submission by the Revenue's counsel that the tax effect in all the appeals was below the minimum threshold limit prescribed by the CBDT circular dated July 11, 2018. This circular provides guidelines for the department regarding the preference and maintenance of appeals before the High Court. Since the condition stipulated in the circular was met, and permission was sought and granted, the appeals were disposed of accordingly. The operative direction was to dispose of the Tax Appeals as withdrawn. No issues were expressly left undecided.

The High Court granted permission to the Revenue to withdraw the appeals. The reasoning provided is that the learned advocate for the Revenue, under instructions from the department, sought permission to withdraw the appeals because the tax effect involved in these appeals was below the minimum threshold limit stipulated by the CBDT in its circular dated 11.07.2018. This circular enables the department to prefer and maintain appeals before the High Court. Consequently, the Tax Appeals were disposed of as withdrawn. No specific issue was decided on merits.

The High Court granted permission to the Revenue to withdraw the appeals. The reasoning provided is that the learned advocate for the Revenue, under instructions from the department, sought permission to withdraw the appeals because the tax effect involved in these appeals was below the minimum threshold limit stipulated by the CBDT in its circular dated 11.07.2018. This circular enables the department to prefer and maintain appeals before the High Court. Consequently, the Tax Appeals were disposed of as withdrawn. No specific issue was decided on merits.

The High Court granted permission to the Revenue to withdraw the appeals. The reasoning provided is that the learned advocate for the Revenue, under instructions from the department, sought permission to withdraw the appeals because the tax effect involved in these appeals was below the minimum threshold limit stipulated by the CBDT in its circular dated 11.07.2018. This circular enables the department to prefer and maintain appeals before the High Court. Consequently, the Tax Appeals were disposed of as withdrawn. No specific issue was decided on merits.

The High Court granted the permission sought by the Revenue to withdraw the appeals. The reasoning was based on the Revenue's submission that the tax effect in all the listed appeals was below the minimum threshold limit stipulated by the CBDT circular dated July 11, 2018. This circular provides guidelines for the department regarding the financial limits for filing and pursuing appeals. Since the condition of the tax effect being below the threshold was met, the Court found no impediment to allowing the withdrawal. The appeals were disposed of accordingly. No specific issue regarding the merits of the original assessment or any other legal question was decided.

The High Court granted the Revenue's request to withdraw the appeals. The reasoning provided was that the learned advocate for the department, under instructions, sought permission to withdraw the appeals because the tax effect involved was below the minimum threshold limit stipulated in the CBDT circular dated 11.07.2018. This circular enables the department to prefer and maintain appeals before the High Court. Consequently, the permission was granted, and the Tax Appeals were disposed of accordingly. No specific findings were made on the merits of the underlying tax disputes, as the appeals were withdrawn.

The High Court granted permission to the Revenue to withdraw the appeals. The Court reasoned that the Revenue's request was based on a CBDT circular dated 11.07.2018, which sets a minimum threshold for the tax effect for preferring and maintaining appeals before the High Court. Since the tax effect in these appeals was below this stipulated limit, the Court allowed the withdrawal. The appeals were disposed of accordingly. No decision was made on the merits of the underlying tax disputes. The ratio decidendi is that appeals with a tax effect below the prescribed threshold, as per CBDT circulars, can be withdrawn by the Revenue.

The High Court granted permission to the Revenue to withdraw the appeals. The Court reasoned that the Revenue's request was based on a CBDT circular dated 11.07.2018, which sets a minimum threshold for the tax effect for preferring and maintaining appeals before the High Court. Since the tax effect in these appeals was below this stipulated limit, the Court allowed the withdrawal. The appeals were disposed of accordingly. No decision was made on the merits of the underlying tax disputes. The ratio decidendi is that appeals with a tax effect below the prescribed threshold, as per CBDT circulars, can be withdrawn by the Revenue.

The High Court granted permission to the Revenue to withdraw the appeals. The reasoning for this decision was based on the Revenue's submission that the tax effect in all the appeals was below the minimum threshold limit stipulated by the CBDT circular dated July 11, 2018. This circular provides guidelines for the department regarding the preference and maintenance of appeals before the High Court. By granting permission, the Court acknowledged the departmental policy and allowed the appeals to be disposed of on this procedural ground, without delving into the merits of the tax disputes. The operative direction was that the Tax Appeals are disposed of accordingly, meaning they are dismissed as withdrawn.

The High Court granted permission to the Revenue to withdraw the appeals. The Court reasoned that the Revenue's request was based on a CBDT circular dated 11.07.2018, which sets a minimum threshold for the tax effect for preferring and maintaining appeals before the High Court. Since the tax effect in these appeals was below this stipulated limit, the Court allowed the withdrawal. The appeals were disposed of accordingly. No decision was made on the merits of the underlying tax disputes. The ratio decidendi is that appeals with a tax effect below the prescribed threshold, as per CBDT circulars, can be withdrawn by the Revenue.

The High Court granted permission to the Revenue to withdraw the appeals. The reasoning for this decision was based on the Revenue's submission that the tax effect in all the appeals was below the minimum threshold limit stipulated by the CBDT circular dated July 11, 2018. This circular provides guidelines for the department regarding the preference and maintenance of appeals before the High Court. By granting permission, the Court acknowledged the departmental policy and allowed the appeals to be disposed of on this procedural ground, without delving into the merits of the tax disputes. The operative direction was that the Tax Appeals are disposed of accordingly, meaning they are dismissed as withdrawn.

The High Court granted permission to the Revenue to withdraw the appeals. The Court reasoned that the Revenue's request was based on a CBDT circular dated 11.07.2018, which sets a minimum threshold for the tax effect for preferring and maintaining appeals before the High Court. Since the tax effect in these appeals was below this stipulated limit, the Court allowed the withdrawal. The appeals were disposed of accordingly. No decision was made on the merits of the underlying tax disputes. The ratio decidendi is that appeals with a tax effect below the prescribed threshold, as per CBDT circulars, can be withdrawn by the Revenue.

The High Court granted permission to the Revenue to withdraw the appeals. The reasoning was based on the Revenue's submission that the tax effect in these appeals fell below the minimum threshold limit prescribed by the CBDT's circular dated 11.07.2018. This circular provides the departmental guidelines for preferring and maintaining appeals before the High Court. Consequently, the Tax Appeals were disposed of as withdrawn. No decision on the merits of the underlying tax disputes was made.

The High Court granted permission to the Revenue to withdraw the appeals. The reasoning was based on the Revenue's submission that the tax effect in these appeals fell below the minimum threshold limit prescribed by the CBDT's circular dated 11.07.2018. This circular provides the departmental guidelines for preferring and maintaining appeals before the High Court. Consequently, the Tax Appeals were disposed of as withdrawn. No decision on the merits of the underlying tax disputes was made.

The High Court granted permission to the Revenue to withdraw the appeals. The Court reasoned that the Revenue's request was based on a CBDT circular dated 11.07.2018, which sets a minimum threshold for the tax effect for preferring and maintaining appeals before the High Court. Since the tax effect in these appeals was below this stipulated limit, the Court allowed the withdrawal. The appeals were disposed of accordingly. No decision was made on the merits of the underlying tax disputes. The ratio decidendi is that appeals with a tax effect below the prescribed threshold, as per CBDT circulars, can be withdrawn by the Revenue.

The High Court granted permission to the Revenue to withdraw the appeals. The reasoning was based on the Revenue's submission that the tax effect in these appeals fell below the minimum threshold limit prescribed by the CBDT's circular dated 11.07.2018. This circular provides the departmental guidelines for preferring and maintaining appeals before the High Court. Consequently, the Tax Appeals were disposed of as withdrawn. No decision on the merits of the underlying tax disputes was made.

The High Court granted permission to the Revenue to withdraw the appeals. The reasoning was based on the Revenue's submission that the tax effect in these appeals fell below the minimum threshold limit prescribed by the CBDT's circular dated 11.07.2018. This circular provides the departmental guidelines for preferring and maintaining appeals before the High Court. Consequently, the Tax Appeals were disposed of as withdrawn. No decision on the merits of the underlying tax disputes was made.

The High Court granted permission to the Revenue to withdraw the appeals. The reasoning was based on the Revenue's submission that the tax effect in these appeals fell below the minimum threshold limit prescribed by the CBDT's circular dated 11.07.2018. This circular provides the departmental guidelines for preferring and maintaining appeals before the High Court. Consequently, the Tax Appeals were disposed of as withdrawn. No decision on the merits of the underlying tax disputes was made.

The High Court granted permission to the Revenue to withdraw the appeals. The Court noted that the learned advocate for the Revenue, under instructions from the department, sought permission to withdraw the appeals because the tax effect involved was below the minimum threshold limit stipulated by the CBDT circular dated 11.07.2018. This circular enables the department to prefer and maintain appeals before the High Court. Consequently, the Tax Appeals were disposed of as withdrawn. No decision was made on the merits of any of the underlying issues.

The High Court granted permission to the Revenue to withdraw the appeals. The Court noted that the learned advocate for the Revenue, under instructions from the department, sought permission to withdraw the appeals because the tax effect involved was below the minimum threshold limit stipulated by the CBDT circular dated 11.07.2018. This circular enables the department to prefer and maintain appeals before the High Court. Consequently, the Tax Appeals were disposed of as withdrawn. No decision was made on the merits of any of the underlying issues.

The High Court granted the permission sought by the Revenue to withdraw the appeals. The reasoning was based on the Revenue's submission that the tax effect in all the appeals was below the minimum threshold limit prescribed by the CBDT circular dated July 11, 2018. This circular provides the guidelines for the department regarding the monetary limits for filing and pursuing appeals. Since the condition stipulated in the circular was met, the Court found no impediment to allowing the withdrawal. Consequently, all the Tax Appeals were disposed of as withdrawn. The Court did not decide on the merits of any of the underlying tax disputes.

The High Court granted the permission sought by the Revenue to withdraw the appeals. The reasoning was based on the Revenue's submission that the tax effect in all the appeals was below the minimum threshold limit prescribed by the CBDT circular dated July 11, 2018. This circular provides the guidelines for the department regarding the monetary limits for filing and pursuing appeals. Since the condition stipulated in the circular was met, the Court found no impediment to allowing the withdrawal. Consequently, all the Tax Appeals were disposed of as withdrawn. The Court did not decide on the merits of any of the underlying tax disputes.

The High Court granted permission to the Revenue to withdraw the appeals. The reasoning provided was that the learned advocate for the Revenue, acting under instructions from the department, sought permission to withdraw the appeals. This request was based on the fact that the tax effect involved in these appeals was below the minimum threshold limit provided by a CBDT circular dated 11.07.2018. This circular dictates the criteria for the department to prefer and maintain appeals before the High Court. Consequently, the Tax Appeals were disposed of in accordance with the permission granted. No specific issue was decided on merits.

The High Court granted permission to the Revenue to withdraw the appeals. The reasoning provided is that the Revenue's instruction to withdraw was based on the CBDT circular dated 11.07.2018, which sets a minimum tax effect threshold for filing and continuing appeals before the High Court. Since the tax effect in these appeals fell below this threshold, the department was enabled to withdraw them. The Court noted that permission was granted and disposed of the Tax Appeals accordingly. No specific findings on the merits of the individual appeals were made as they were withdrawn.