Gujarat High Court Judgments — 2018

The High Court granted permission to the Revenue to withdraw the appeals. The Court acknowledged the Revenue's submission that the tax effect in these appeals was below the minimum threshold limit set by the CBDT's circular dated 11.07.2018. This circular provides guidelines for the department regarding the monetary limits for preferring and maintaining appeals before higher courts. By granting permission, the Court implicitly accepted the department's administrative decision to withdraw appeals based on the tax effect not meeting the specified threshold. The appeals were disposed of accordingly. No specific issue on merits was decided.

The High Court granted permission to the Revenue to withdraw the appeals. The Court acknowledged the Revenue's submission that the tax effect in these appeals was below the minimum threshold limit set by the CBDT's circular dated 11.07.2018. This circular provides guidelines for the department regarding the monetary limits for preferring and maintaining appeals before higher courts. By granting permission, the Court implicitly accepted the department's administrative decision to withdraw appeals based on the tax effect not meeting the specified threshold. The appeals were disposed of accordingly. No specific issue on merits was decided.

The High Court of Gujarat at Ahmedabad, per the oral order of Justices Akil Kureshi and B.N. Karia, granted permission to the appellant (Revenue) to withdraw the Tax Appeals. The Revenue's submission was that the tax effect in these appeals fell below the threshold limit stipulated by the CBDT in its circular dated 11.07.2018, which governs the department's ability to file and maintain appeals before the High Court. The Court accepted this submission and disposed of the Tax Appeals accordingly. No decision was made on the merits of the underlying tax disputes. The ratio decidendi is that appeals can be withdrawn by the Revenue if they do not meet the monetary limits prescribed by CBDT circulars for maintaining such appeals.

The High Court of Gujarat, in light of the pronouncement of the Apex Court in Union of India and Others vs. Ashish Agarwal, ordered all the captioned writ petitions to be disposed of without adjudication on merit. The Apex Court's order, which was made applicable PAN India, held that impugned Section 148 notices issued under the unamended Section 148 of the IT Act shall be deemed to have been issued under Section 148A of the IT Act as substituted by the Finance Act, 2021, and construed as show-cause notices under Section 148A(b). The Assessing Officer was directed to provide information to assessees within thirty days, allowing them two weeks to reply. The requirement of conducting an enquiry with prior approval under Section 148A(a) was dispensed with as a one-time measure for notices issued from 01.04.2021 till date. Thereafter, Assessing Officers were to pass orders under Section 148A(d) and then issue notices under the substituted Section 148. All defenses available to assessees and the Revenue were preserved. The High Court clarified that if any other issue existed in the petitions beyond Section 148, liberty was reserved to file fresh petitions.

The High Court granted the Revenue's request to withdraw the appeals. The Court noted that the Revenue, acting under instructions from the department, sought permission to withdraw the appeals because the tax effect involved was below the minimum threshold limit set by the CBDT in its circular dated 11.07.2018. This circular enables the department to refrain from preferring and maintaining appeals before the High Court when the tax effect is below the prescribed limit. Consequently, the Court granted the permission sought and disposed of the Tax Appeals accordingly. No specific findings on the merits of the individual appeals were made, as the withdrawal was based on administrative policy and monetary limits.

The High Court dismissed the Revenue's appeal. The Court noted that a partner of the assessee firm, in response to a query about the undisclosed income of Rs. 35 crores, had stated that it was earned from land-related transactions and was not recorded in the books. The partner also indicated that a detailed breakup would be submitted after accessing bank lockers. The Court found this response to be in sufficient compliance with the requirement of establishing the manner in which the income was earned. The Court also acknowledged that the AO had made additions taxing admitted amounts. Therefore, the Court concluded that there was substantial compliance by the assessee. While the Tribunal's reasoning was not fully endorsed, the Court found no reason to disturb the ITAT's order. The issue of penalty in relation to additions made outside the assessee's disclosures was left open, as the quantum of such penalty was not significant.

The High Court granted permission to the Revenue to withdraw the tax appeals. The reasoning was based on the Revenue's submission that the tax effect 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. The Court accepted this reason and disposed of the appeals accordingly. The ratio decidendi is that appeals can be withdrawn by the Revenue if they do not meet the monetary limits prescribed by administrative instructions like CBDT circulars, provided permission is sought and granted by the court. No specific issue was left undecided as the appeals were withdrawn.

The High Court held that the Revenue was permitted to withdraw the tax appeals. The Court granted the permission sought by the learned advocate for the appellant (Revenue) to withdraw the appeals. The reasoning was based on the Revenue's submission that the tax effect in these appeals was below the minimum threshold limit stipulated by the CBDT in its circular dated 11.07.2018, which allows the department to withdraw or not pursue appeals before the High Court. Consequently, the Tax Appeals were disposed of as withdrawn. No specific issue regarding the merits of the original tax disputes was decided.

The High Court granted the Revenue's request to withdraw the appeals. The Court reasoned that the Revenue, acting under instructions from the department, sought permission to withdraw these appeals because the tax effect involved was below the minimum threshold limit prescribed 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 reason sufficient to permit withdrawal. Consequently, the Tax Appeals were disposed of accordingly. No specific issue regarding the merits of the original tax disputes was decided.

The High Court of Gujarat dismissed all the tax appeals filed by the Revenue. The dismissal was solely on the ground that the tax effect involved in these appeals was below the minimum threshold stipulated by the CBDT in its circular dated 11.7.2018. This circular specifies the monetary limit for the Revenue to maintain appeals before the High Court. As the appeals did not meet this threshold, they were considered not maintainable. The Court did not delve into the merits of the substantive tax issues that might have been raised in the appeals. The operative direction was the dismissal of the appeals. No issue was expressly left undecided, as the appeals were disposed of on a procedural/jurisdictional ground.

The High Court dismissed the appeals filed by the Revenue. The Court noted that it was informed that the tax effect involved in these appeals was below the minimum threshold prescribed by the CBDT in its latest circular dated 11.7.2018 for the Revenue to maintain appeals before the High Court. Consequently, the appeals were dismissed solely on this ground, without delving into the merits of the case. No specific finding was made on the substantive tax issues.

The High Court of Gujarat dismissed all the tax appeals filed by the Revenue. The dismissal was solely on the ground that the tax effect involved in these appeals was below the minimum threshold stipulated by the CBDT in its circular dated 11.7.2018. This circular specifies the monetary limit for the Revenue to maintain appeals before the High Court. As the appeals did not meet this threshold, they were considered not maintainable. The Court did not delve into the merits of the substantive tax issues that might have been raised in the appeals. The operative direction was the dismissal of the appeals. No issue was expressly left undecided, as the appeals were disposed of on a procedural/jurisdictional ground.

The High Court of Gujarat dismissed all the tax appeals filed by the Revenue. The sole ground for dismissal was that the tax effect involved in these appeals was below the minimum monetary threshold stipulated by the Central Board of Direct Taxes (CBDT) in its circular dated 11.7.2018. This circular prescribes the limit for the Revenue to maintain appeals before the High Court. Since the appeals did not meet this threshold, they were deemed not maintainable and were consequently dismissed. The court did not delve into the merits of any of the substantive tax issues that might have been raised in the appeals. The ratio decidendi is that appeals filed by the Revenue that do not meet the prescribed monetary limit as per CBDT circulars are liable to be dismissed on this procedural ground.

The High Court dismissed the appeals filed by the Revenue. The Court noted that it was informed that the tax effect involved in these appeals was below the minimum threshold prescribed by the CBDT in its latest circular dated 11.7.2018 for the Revenue to maintain appeals before the High Court. Consequently, the appeals were dismissed solely on this ground, without delving into the merits of the case. No specific finding was made on the substantive tax issues.

The High Court granted permission to the Revenue to withdraw the tax appeals. The Court noted that the learned advocate for the appellant (Revenue), under instructions from the department, sought permission to withdraw these appeals. The reason provided was that 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. The Court found this reason sufficient and granted the permission. Consequently, all the listed Tax Appeals were disposed of as withdrawn. No decision was made on the merits of the underlying tax disputes.

The High Court held that the Revenue was permitted to withdraw the tax appeals. The Court granted the permission sought by the learned advocate for the appellant (Revenue) to withdraw the appeals. The reasoning was based on the Revenue's submission that the tax effect in these appeals was below the minimum threshold limit stipulated by the CBDT in its circular dated 11.07.2018, which allows the department to withdraw or not pursue appeals before the High Court. Consequently, the Tax Appeals were disposed of as withdrawn. No specific issue regarding the merits of the original tax disputes was decided.

The Tribunal held that the Commissioner of Income-tax erred in exercising revisional powers under Section 263. Regarding the first issue, the Tribunal found that the determination of the net profit rate was a subject matter of appeal before the CIT(Appeals). As per Clause (c) of Explanation 1 to Section 263(1), the Commissioner's revisional powers do not extend to matters already considered and decided in an appeal arising from the assessment order. Therefore, the Commissioner could not revise the order on the profit estimation rate. Regarding the second issue concerning statutory payments, the Tribunal noted that while the Assessing Officer had considered various aspects, including TDS on payments, and arrived at a holistic net profit percentage, the Commissioner's order was based on a mere possibility of non-allowability of expenditure without collecting proof of payment. The Commissioner did not prima facie conclude that the expenditure was not allowable due to non-deposit. The Tribunal clarified that this did not amount to an unconditional acceptance of the contention that no disallowance is permissible once book results are rejected and profit is estimated. The appeal was dismissed.

The High Court granted the Revenue's request to withdraw the appeals. The Court reasoned that the Revenue, acting under instructions from the department, sought permission to withdraw these appeals because the tax effect involved was below the minimum threshold limit prescribed 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 reason sufficient to permit withdrawal. Consequently, the Tax Appeals were disposed of accordingly. No specific issue regarding the merits of the original tax disputes was decided.

The High Court decided to dismiss the Tax Appeals filed by the Revenue. The sole ground for dismissal was that the tax effect involved in these appeals was below the minimum threshold prescribed by the CBDT in its circular dated July 11, 2018. This circular governs the conditions under which the Revenue can maintain appeals before the High Court. The Court explicitly stated that the appeals were dismissed 'only on this ground,' indicating no adjudication on the merits of the substantive tax issues. The ratio decidendi is that appeals filed by the Revenue that do not meet the monetary threshold stipulated by the relevant CBDT circular are liable to be dismissed on that procedural ground. No specific operative directions were issued other than the dismissal of the appeals.

The High Court of Gujarat dismissed all the tax appeals filed by the Revenue. The dismissal was solely on the ground that the tax effect involved in these appeals was below the minimum threshold stipulated by the CBDT in its circular dated 11.7.2018. This circular specifies the monetary limit for the Revenue to maintain appeals before the High Court. As the appeals did not meet this threshold, they were considered not maintainable. The Court did not delve into the merits of the substantive tax issues that might have been raised in the appeals. The operative direction was the dismissal of the appeals. No issue was expressly left undecided, as the appeals were disposed of on a procedural/jurisdictional ground.

The High Court granted permission to the Revenue to withdraw the tax appeals. The Court acknowledged the Revenue's submission that the tax effect in these appeals was below the minimum threshold limit stipulated by the CBDT in its circular dated July 11, 2018. This circular provides the departmental guidelines for preferring and maintaining appeals before the High Court. Consequently, the Court disposed of all the listed Tax Appeals accordingly. No specific findings were made on the merits of the individual appeals, as the withdrawal was based on administrative policy and monetary limits set by the CBDT.

The High Court dismissed all the tax appeals filed by the Revenue. The sole ground for dismissal was that the tax effect involved in these appeals was below the minimum monetary threshold stipulated by the Central Board of Direct Taxes (CBDT) in its circular dated 11.7.2018. This circular sets the limit for the Revenue to file appeals before the High Court. Since the appeals did not meet this threshold, the Court found no reason to entertain them on merits. The judgment explicitly states that the appeals are dismissed 'only on this ground,' implying no decision was made on the substantive tax issues.

The High Court of Gujarat granted permission to the Revenue to withdraw the tax appeals. The Court noted that the learned advocate for the appellant, acting under instructions from the department, sought permission to withdraw these appeals. The reason provided for withdrawal was that 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 Court granted the permission sought, and the Tax Appeals were disposed of accordingly. No decision was made on the merits of any of the underlying tax disputes.

The High Court granted permission to the Revenue to withdraw the tax appeals. The Court acknowledged the Revenue's submission that the tax effect in these appeals was below the minimum threshold limit stipulated by the CBDT in its circular dated July 11, 2018. This circular provides the departmental guidelines for preferring and maintaining appeals before the High Court. Consequently, the Court disposed of all the listed Tax Appeals accordingly. No specific findings were made on the merits of the individual appeals, as the withdrawal was based on administrative policy and monetary limits set by the CBDT.

The High Court held that the tax effect involved in these appeals filed by the Revenue was below the minimum threshold prescribed by the CBDT in its circular dated 11.7.2018 for maintaining appeals before the High Court. Consequently, the Court dismissed all the Tax Appeals solely on this ground. The reasoning is that the CBDT circular sets a mandatory condition for the Revenue to file appeals, and non-compliance with this condition renders the appeal non-maintainable. The ratio decidendi is that appeals filed by the Revenue that do not meet the monetary limit stipulated by the CBDT circular are liable to be dismissed without delving into the merits of the case. No specific relief was granted to the assessee as the appeals were dismissed on a procedural technicality. No issues were left undecided.

The High Court held that the tax effect involved in these appeals filed by the Revenue was below the minimum threshold prescribed by the CBDT in its latest circular dated 11.7.2018. This circular specifies the monetary limit for the Revenue to maintain appeals before the High Court. Consequently, the appeals were dismissed solely on this ground. The Court did not delve into the merits of the substantive tax issues that might have been raised in the appeals. The ratio decidendi is that appeals filed by the Revenue that do not meet the prescribed tax effect threshold are not maintainable and will be dismissed on that procedural basis.

The High Court dismissed all the tax appeals filed by the Revenue. The sole ground for dismissal was that the tax effect involved in these appeals was below the minimum monetary threshold stipulated by the Central Board of Direct Taxes (CBDT) in its circular dated 11.7.2018. This circular sets the limit for the Revenue to file appeals before the High Court. Since the appeals did not meet this threshold, the Court found no reason to entertain them on merits. The judgment explicitly states that the appeals are dismissed 'only on this ground,' implying no decision was made on the substantive tax issues.

The High Court granted permission to the Income Tax Officer to withdraw the appeals. The reasoning was based on the revenue's submission that the tax effect in these appeals was below the minimum threshold limit prescribed by the CBDT's circular dated 11.07.2018. This circular provides guidelines for the department regarding the monetary limits for filing and pursuing appeals. Since the condition stipulated in the circular was not met, the department was permitted to withdraw the appeals. The appeals were disposed of accordingly. No specific finding was made on the merits of any tax dispute, as the appeals were withdrawn before any substantive adjudication.

The High Court of Gujarat dismissed all the tax appeals filed by the Revenue. The sole ground for dismissal was that the tax effect involved in these appeals was below the minimum monetary threshold stipulated by the Central Board of Direct Taxes (CBDT) in its circular dated 11.7.2018. This circular prescribes the limit for the Revenue to maintain appeals before the High Court. Since the appeals did not meet this threshold, they were deemed not maintainable and were consequently dismissed. The court did not delve into the merits of any of the substantive tax issues that might have been raised in the appeals. The ratio decidendi is that appeals filed by the Revenue that do not meet the prescribed monetary limit as per CBDT circulars are liable to be dismissed on this procedural ground.

The High Court of Gujarat dismissed all the tax appeals filed by the Revenue. The dismissal was solely on the ground that the tax effect involved in these appeals was below the minimum threshold stipulated by the CBDT in its circular dated 11.7.2018. This circular specifies the monetary limit for the Revenue to maintain appeals before the High Court. As the appeals did not meet this threshold, they were considered not maintainable. The Court did not delve into the merits of the substantive tax issues that might have been raised in the appeals. The operative direction was the dismissal of the appeals. No issue was expressly left undecided, as the appeals were disposed of on a procedural/jurisdictional ground.

The High Court of Gujarat, per the oral order, granted the permission sought by the learned advocate for the appellant (Revenue) to withdraw the appeals. The reasoning provided was that the tax effect involved in these appeals was below the minimum threshold limit specified in the CBDT circular dated July 11, 2018. This circular enables the department to prefer and maintain appeals before the High Court only if the tax effect meets the prescribed limit. Therefore, the appeals were disposed of as withdrawn. No decision on the merits of the substantive tax issues was made. The ratio decidendi is that appeals can be withdrawn by the Revenue if they do not meet the monetary threshold for litigation as per CBDT circulars, irrespective of the merits of the case.

The High Court granted permission to the Revenue to withdraw the appeals. The reasoning provided is that the tax effect involved in these appeals is 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 Tax Appeals were disposed of as withdrawn. The ratio decidendi is that appeals can be withdrawn by the Revenue if they do not meet the monetary limits set by the CBDT for maintaining such appeals. No specific issues regarding the merits of the tax disputes were decided.

The High Court granted permission to the Income Tax Officer to withdraw the appeals. The reasoning provided is that the tax effect in these appeals falls below the minimum threshold limit stipulated by the CBDT in its circular dated 11.07.2018. This circular provides guidelines for the department regarding the monetary limits for filing and maintaining appeals before higher judicial forums, including the High Court. Consequently, the appeals were disposed of as withdrawn based on this administrative instruction and the Revenue's request.

The High Court dismissed the appeals filed by the Revenue. The Court distinguished the present case from a previous judgment in Futura Ceramics, where reassessment was quashed because it was based solely on an excise show-cause notice without further verification and before the excise proceedings concluded. In the present case, the Court noted that the AO had elicited the assessee's response to the excise show-cause notice. The Court also rejected the contention that the AO must wait for the finalization of excise proceedings, stating that excise adjudication does not have the same time-barring provisions as the Income Tax Act, and deferring assessment could lead to it becoming time-barred. The Court found that the AO's actions were permissible. The ratio is that an AO can proceed with assessment based on information from other departments, provided the assessee is given an opportunity to respond, and the AO is not obligated to await the final outcome of parallel proceedings if it risks the assessment becoming time-barred.

The High Court of Gujarat, in its oral order, held that the tax effect involved in these appeals filed by the Revenue was below the minimum threshold prescribed by the CBDT in its circular dated 11.7.2018. This circular specifies the monetary limits for the Revenue to maintain appeals before the High Court. Consequently, the Court dismissed all the Tax Appeals solely on this ground. The ratio decidendi is that appeals filed by the Revenue that do not meet the minimum tax effect threshold stipulated by the CBDT circular are not maintainable and will be dismissed on that basis. No other issues were decided on merits.

The High Court held that the appeals filed by the Revenue were to be dismissed solely on the ground that the tax effect involved was below the minimum threshold stipulated by the CBDT circular dated 11.07.2018. The Court noted that this circular sets the limit for maintaining appeals before the High Court. Therefore, the appeals were dismissed on this procedural ground without delving into the merits of the case. No other issues were decided, and no specific relief was granted or denied on the substantive tax matters.

The High Court granted permission to the Revenue to withdraw the appeals. The reasoning provided is that the tax effect involved in these appeals is 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 Tax Appeals were disposed of as withdrawn. The ratio decidendi is that appeals can be withdrawn by the Revenue if they do not meet the monetary limits set by the CBDT for maintaining such appeals. No specific issues regarding the merits of the tax disputes were decided.

The High Court granted permission to the Revenue to withdraw the appeals. The reasoning provided is that the tax effect involved in these appeals is below the minimum threshold limit stipulated by the CBDT in its circular dated 11.07.2018. This circular provides the basis for the department to prefer and maintain appeals before the High Court. Since the condition for maintaining the appeal, as per the circular, was not met due to the low tax effect, the court allowed the withdrawal. The appeals were disposed of accordingly. No specific issue was decided on merits, and no operative directions for remand or deletion were issued.

The High Court granted permission to the Revenue to withdraw the appeals. The reasoning provided was that the tax effect involved in all the appeals was below the minimum threshold limit prescribed by the Central Board of Direct Taxes (CBDT) in its circular dated 11.07.2018. This circular enables the department to prefer and maintain appeals before the High Court. Since the condition for maintaining appeals based on tax effect was not met, the Revenue was permitted to withdraw them. The appeals were disposed of accordingly. No specific findings were made on the merits of the underlying tax disputes, and no issue was left undecided as the appeals were withdrawn by the appellant.

The High Court held that the Revenue was permitted to withdraw the appeals. The reasoning was based on the Revenue's submission that 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 empowers the department to prefer and maintain appeals before the High Court. Consequently, the Court granted the permission sought by the learned advocate for the appellant (Revenue) and disposed of the Tax Appeals accordingly. No specific finding was made on the merits of the original tax disputes, as the appeals were withdrawn based on administrative policy regarding tax effect thresholds.

The High Court of Gujarat held that the tax effect involved in all the appeals filed by the Revenue was below the minimum threshold prescribed by the CBDT in its circular dated 11.7.2018. This circular specifies the monetary limits for the Revenue to maintain appeals before the High Court. Consequently, the Court found that the Revenue was not entitled to maintain these appeals. The appeals were therefore dismissed solely on this procedural ground, without delving into the merits of the substantive tax issues. The ratio decidendi is that appeals filed by the Revenue that do not meet the minimum tax effect threshold stipulated by the CBDT circulars are liable to be dismissed on that basis. The operative direction was to dismiss the Tax Appeals.

The High Court of Gujarat, comprising Justices Akil Kureshi and B.N. Karia, dismissed all the tax appeals filed by the Revenue. The sole ground for dismissal was that the tax effect involved in these appeals was below the minimum threshold stipulated by the Central Board of Direct Taxes (CBDT) in its circular dated 11.7.2018. This circular sets the monetary limit for the Revenue to file appeals before the High Court. Since the appeals did not meet this prescribed threshold, the court found no merit in entertaining them. The ratio decidendi is that appeals filed by the Revenue that do not meet the minimum tax effect threshold mandated by CBDT circulars are liable to be dismissed on that procedural ground alone, without delving into the merits of the case.

The High Court dismissed the Tax Appeals filed by the Revenue. The sole ground for dismissal was that the tax effect involved in these appeals was below the minimum threshold prescribed by the CBDT in its circular dated 11.7.2018. This circular sets the limit for the Revenue to maintain appeals before the High Court. Since the appeals did not meet this monetary threshold, the Court found no reason to proceed with the merits of the case. The ratio decidendi is that appeals filed by the Revenue that do not meet the prescribed minimum tax effect, as per CBDT circulars, are liable to be dismissed on this preliminary ground. No specific relief was granted to the assessee as the appeals were dismissed on a procedural technicality.

The High Court held that the tax effect involved in these appeals filed by the Revenue was below the minimum threshold prescribed by the CBDT in its circular dated 11.07.2018. This circular specifies the monetary limit for the Revenue to maintain appeals before the High Court. Consequently, the appeals were dismissed solely on this procedural ground. The court did not delve into the merits of the substantive tax issues. The ratio decidendi is that appeals filed by the Revenue that do not meet the minimum tax effect threshold stipulated by the CBDT are liable to be dismissed on that basis alone, without examining the underlying tax disputes. No specific issue was left undecided, as the appeals were disposed of on a preliminary procedural point.

The High Court granted permission to the Revenue to withdraw the appeals. The reasoning provided was that the tax effect in these appeals fell below the minimum threshold limit stipulated by the CBDT circular dated 11.07.2018. This circular empowers the department to withdraw or not pursue appeals where the tax effect is below a certain amount. Consequently, the appeals were disposed of as withdrawn. No specific findings on the merits of any tax dispute were made, 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 tax appeals. The Court noted that the learned advocate for the appellant (Revenue), under instructions from the department, sought permission to withdraw these appeals. The reason cited was that 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 empowers the department to prefer and maintain appeals before the High Court. The Court found this reason sufficient and accordingly granted the permission. The appeals were disposed of as permitted. The judgment does not delve into the merits of the original disputes that led to the appeals before the ITAT or the High Court, nor does it discuss any specific findings of the ITAT. The operative direction was to dispose of the Tax Appeals as withdrawn.

The High Court of Gujarat, in its oral order, held that the tax effect involved in these appeals filed by the Revenue was below the minimum threshold prescribed by the CBDT in its circular dated 11.7.2018. This circular specifies the monetary limits for the Revenue to maintain appeals before the High Court. Consequently, the Court dismissed all the Tax Appeals solely on this ground. The ratio decidendi is that appeals filed by the Revenue that do not meet the minimum tax effect threshold stipulated by the CBDT circular are not maintainable and will be dismissed on that basis. No other issues were decided on merits.

The High Court granted permission to the Revenue to withdraw the appeals. The Court acknowledged the Revenue's submission that the tax effect in these appeals was below the minimum threshold limit specified in the CBDT Circular dated 11.07.2018. This circular empowers the department to withdraw or not pursue appeals where the tax effect falls below the prescribed limit. Consequently, the Court disposed of all the Tax Appeals accordingly. No specific findings on the merits of the original tax disputes were made, as the appeals were withdrawn based on administrative policy regarding monetary limits for litigation.

The High Court granted permission to the Revenue to withdraw the appeals. The Court acknowledged the Revenue's submission that the tax effect in these appeals was below the minimum threshold limit specified in the CBDT Circular dated 11.07.2018. This circular empowers the department to withdraw or not pursue appeals where the tax effect falls below the prescribed limit. Consequently, the Court disposed of all the Tax Appeals accordingly. No specific findings on the merits of the original tax disputes were made, as the appeals were withdrawn based on administrative policy regarding monetary limits for litigation.

The High Court granted permission to the Revenue to withdraw the tax appeals. The Court acknowledged the Revenue's submission that the tax effect in these appeals was below the minimum threshold limit stipulated by the CBDT in its circular dated July 11, 2018. This circular empowers the department to prefer and maintain appeals before the High Court. Consequently, the Court disposed of all the Tax Appeals as withdrawn. The specific tax effect amounts or the assessment years for which these appeals were filed were not detailed in the judgment, nor were any specific legal provisions discussed beyond the reference to the CBDT circular.