Gujarat High Court Judgments — 2018

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 appeals. The reasoning was based on the Revenue's submission that the tax effect in these appeals was below the minimum threshold limit set by the CBDT in its circular dated July 11, 2018. This circular allows the department to withdraw or not pursue appeals where the tax effect is below a certain amount, thereby streamlining litigation and focusing resources on cases with higher stakes. The Court found this reason valid and disposed of the Tax Appeals accordingly. No decision was made on the merits of the original tax disputes.

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 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 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 permission to the Revenue to withdraw the tax appeals. The reasoning provided is that the learned advocate for the appellant, 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 specified in the CBDT Circular dated 11.07.2018. This circular enables the department to prefer and maintain appeals before the High Court. Consequently, the appeals were disposed of as withdrawn. No specific issue was decided on merits.

The High Court dismissed the appeals filed by the Revenue. The Court acknowledged that the AO had not proceeded solely on the basis of the Excise Department's show-cause notice but had elicited the assessee's response to the contents of that notice. The Court rejected the assessee's argument (as seen in the prior case) that the AO could not pass a final assessment order until the excise proceedings were finalized, stating that the AO cannot defer assessment indefinitely due to potential time-barring provisions under the Income Tax Act. The Court also noted that the material in excise proceedings might differ from that in assessment proceedings. The operative direction was the dismissal of the appeals.

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 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 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 appeals, following its earlier order in a batch of similar Tax Appeals. The Court held that the Assessing Officer had not sufficiently established the material for making additions. While the Assessing Officer confronted the assessee with the contents of the Excise Department's show-cause notice and accompanying statements, this material, which was yet to be adjudicated by the Excise authorities, did not automatically get established. The Court found that the Assessing Officer had done little else to independently bring material on record and had virtually shifted the burden of proving evasion onto the assessee. The Court noted that the excise show-cause notices were at a preliminary stage and their final outcome was uncertain. Therefore, the Assessing Officer lacked sufficient basis for making additions. The question of the percentage of sales at which additions should be made was rendered redundant. The Court decided the issue against the Revenue.

The Tribunal confirmed the view that the larger interest income offered by the assessee subsumed the error component of Rs. 23,08,970, and therefore, no question of law arose on this issue. Regarding the claim for depreciation on assets purchased out of exempted income under Section 35AC, the Tribunal reversed the Assessing Officer's decision. The Tribunal relied on the Supreme Court's decision in CIT v. Rajasthan and Gujarati Charitable Foundation, which held that depreciation is allowable on assets even if the income used for their purchase is eligible for exemption under Section 11. The Tribunal reasoned that Section 35AC provides exemption for expenditure incurred on eligible projects, while Section 32 allows depreciation on tangible assets owned and used for business or profession. The conditions for claiming depreciation under Section 32 were satisfied in this case, and the exemption under Section 35AC did not preclude the claim for depreciation. The appeal was dismissed.

The High Court agreed with the view of the Income Tax Appellate Tribunal. The Tribunal had held that the assessee had not concealed any particulars of its income. Regarding the receipts in the form of sales tax and excise duty concessions, the assessee had followed its own interpretation, believing them to be capital in nature and not chargeable for the computation of book profit under Section 115JB. The Tribunal was of the opinion that two views were possible, and the assessee had held a bona fide belief and acted accordingly. Therefore, there was no failure on the part of the assessee to conceal any particulars of income. The High Court found no case of law arising and dismissed the Tax Appeals.

The High Court agreed with the view of the Income Tax Appellate Tribunal. The Tribunal had held that the assessee had not concealed any particulars of its income. Regarding the receipts in the form of sales tax and excise duty concessions, the assessee had followed its own interpretation, believing them to be capital in nature and not chargeable for the computation of book profit under Section 115JB. The Tribunal was of the opinion that two views were possible, and the assessee had held a bona fide belief and acted accordingly. Therefore, there was no failure on the part of the assessee to conceal any particulars of income. The High Court found no case of law arising and dismissed the Tax Appeals.

The High Court dismissed the appeals filed by the Revenue. The Court observed that in similar situations, it had previously dismissed a bunch of Tax Appeals by a common order dated April 25, 2018. In those cases, the Court found that the Assessing Officer had not proceeded on the basis of a finalized show-cause notice from the Excise Department. The AO had merely confronted the assessee with the contents of the show-cause notice and elicited a response, but had not brought independent material on record to establish the veracity of the statements collected by the Excise Department. The Court held that merely producing copies of statements accompanying a show-cause notice does not automatically establish their truthfulness. The AO had virtually shifted the burden of proving evasion onto the assessee without independent verification. The Court also noted that the excise proceedings were not finalized and the material therein was yet to be tested. Therefore, the AO lacked sufficient material to make additions, rendering the question of the percentage of sales for additions redundant. The Court concluded that the Assessing Officer did not have the basis for making additions, and thus, the question was decided against the Revenue.

The High Court dismissed the appeals filed by the Revenue. The Court observed that in similar situations, it had previously dismissed a bunch of Tax Appeals by a common order dated April 25, 2018. In those cases, the Court found that the Assessing Officer had not proceeded on the basis of a finalized show-cause notice from the Excise Department. The AO had merely confronted the assessee with the contents of the show-cause notice and elicited a response, but had not brought independent material on record to establish the veracity of the statements collected by the Excise Department. The Court held that merely producing copies of statements accompanying a show-cause notice does not automatically establish their truthfulness. The AO had virtually shifted the burden of proving evasion onto the assessee without independent verification. The Court also noted that the excise proceedings were not finalized and the material therein was yet to be tested. Therefore, the AO lacked sufficient material to make additions, rendering the question of the percentage of sales for additions redundant. The Court concluded that the Assessing Officer did not have the basis for making additions, and thus, the question was decided against the Revenue.

The High Court held that the Assessing Officer (AO) did not have sufficient material to make additions to the assessee's income. The Court noted that the AO had primarily relied on the show-cause notices issued by the Excise Department and statements collected therein. However, these notices had not yet culminated into final orders, meaning the allegations were still to be established through quasi-judicial proceedings. The Court found that the AO had merely confronted the assessee with these materials and elicited a brief denial, without independently verifying the statements or bringing any further material on record. The Court observed that merely producing copies of statements accompanying show-cause notices does not automatically establish their veracity. The AO's actions were considered cosmetic, virtually shifting the burden of proof of evasion onto the assessee. Consequently, the Court found no basis for the AO to make additions. The question of the percentage of sales at which additions should be made was rendered redundant. The Court dismissed all the appeals filed by the Revenue.

The High Court held that the Assessing Officer (AO) did not have sufficient material to make additions to the assessee's income. The Court noted that the AO had primarily relied on the show-cause notices issued by the Excise Department and statements collected therein. However, these notices had not yet culminated into final orders, meaning the allegations were still to be established through quasi-judicial proceedings. The Court found that the AO had merely confronted the assessee with these materials and elicited a brief denial, without independently verifying the statements or bringing any further material on record. The Court observed that merely producing copies of statements accompanying show-cause notices does not automatically establish their veracity. The AO's actions were considered cosmetic, virtually shifting the burden of proof of evasion onto the assessee. Consequently, the Court found no basis for the AO to make additions. The question of the percentage of sales at which additions should be made was rendered redundant. The Court dismissed all the appeals filed by the Revenue.

The High Court held that the Assessing Officer (AO) did not have sufficient material to make additions to the assessee's income. The Court noted that the AO had primarily relied on the show-cause notices issued by the Excise Department and statements collected therein. However, these notices had not yet culminated into final orders, meaning the allegations were still to be established through quasi-judicial proceedings. The Court found that the AO had merely confronted the assessee with these materials and elicited a brief denial, without independently verifying the statements or bringing any further material on record. The Court observed that merely producing copies of statements accompanying show-cause notices does not automatically establish their veracity. The AO's actions were considered cosmetic, virtually shifting the burden of proof of evasion onto the assessee. Consequently, the Court found no basis for the AO to make additions. The question of the percentage of sales at which additions should be made was rendered redundant. The Court dismissed all the appeals filed by the Revenue.

The High Court held that the reasons recorded by the Assessing Officer for re-opening the assessment lacked validity. While acknowledging that the concept of change of opinion does not apply to assessments accepted under Section 143(1), the court emphasized the continued relevance of the 'reason to believe' standard under Section 147. The AO had queried the cash deposits, and the assessee had explained that these deposits were from withdrawals from her own bank accounts, with withdrawals closely matching deposits. The AO's reasons for reopening completely ignored this explanation provided by the assessee in response to pre-notice queries. The court found that the AO had not provided any material to discard the assessee's explanation and thus proceeded on an erroneous premise. Consequently, the impugned notice of reopening was quashed. The ratio is that reasons for reopening must consider and address the assessee's explanations provided in response to pre-notice queries, and cannot simply ignore them.

The High Court held that in view of the Revenue's withdrawal of the show-cause notice and the order passed thereunder, no further orders were required to be passed in the present petition. The court explicitly stated that the disposal of the petition would not prevent the department from initiating fresh action under Section 179(1) of the Income Tax Act, 1961, if legally permissible and warranted by facts. The court made it clear that it was expressing no opinion on the merits of any potential fresh action. The petition was disposed of on this basis.

The High Court held that in view of the Revenue's withdrawal of the show-cause notice and the order passed under Section 179(1) of the Income Tax Act, 1961, no further order was required to be passed in the petition. The Court clarified that the disposal of the petition would not prevent the department from initiating fresh action under Section 179(1) if legally permissible and factually warranted. The Court explicitly stated that it was expressing no opinion on the merits of any such potential fresh action. The operative direction was to dispose of the petition.

The High Court dismissed the Tax Appeal. The Court noted that the issue arose from an assessment order passed by the Assessing Officer pursuant to a revisional order of the Commissioner under Section 263 of the Income-tax Act, 1961. The Tribunal had set aside the revisional order of the Commissioner. Consequently, the Tribunal held that the assessment order passed by the Assessing Officer would not survive. The High Court was informed that the Revenue's Tax Appeal No. 967 of 2017, against the Tribunal's order reversing the revisional order of the Commissioner, had already been dismissed by the High Court on December 11, 2017. Given this prior dismissal, the present Tax Appeal was also dismissed.

The High Court dismissed the appeal. The Court referred to its own decision in Commissioner of Income Tax vs. Gujarat State Road Transport Corporation ([2014] 366 ITR 170 [Guj.]), which dealt with the identical issue. In that decision, the Court had held that for sums received from employees to which Section 2(24)(x) applies, a deduction under Section 28 is permissible only if such sums are credited by the assessee to the employees' account in the relevant fund on or before the due date specified in the explanation to Section 36(1)(va). Consequently, the Court held that the Tribunal had erred in deleting the disallowances made by the AO when such sums were not credited to the employees' accounts in the Provident Fund or ESI Fund on or before the due date. The ratio is that the timing of crediting the employees' contribution to the respective funds is crucial for claiming deduction, and failure to meet the statutory due date leads to disallowance.

The High Court held that no question of law arises from the ITAT's order. The Court referred to its prior decision in Principal Commissioner of Income-Tax v. Shri Mahila Sewa Sahakari Bank Limited, which dealt with a similar issue concerning accrued interest on NPAs for a cooperative bank following the mercantile system of accounting. In that precedent, the Division Bench had dismissed the Revenue's appeal. Therefore, following its own established precedent, the High Court found no merit in the Revenue's appeals. The appeals were dismissed on the grounds that they did not raise a substantial question of law.

The High Court disposed of the appeal based on a statement made by the assessee's counsel. The counsel stated that the disputed amount of Rs.76,93,176/- was offered to tax in Assessment Year 2013-14 when it was actually repaid, and the Revenue had accepted this position. The Court acknowledged that in tax matters, the correct year of taxation is important. However, considering that the disputed sum was below the tax limit prescribed by the CBDT and that the tax had already been deposited in a later year, the Court found it appropriate to close the appeal. The Court noted that if the Assessing Officer found any confusion regarding the actual interest being taxed in the later year, they could file a recall application. The specific legal questions regarding the allowability of the deduction on the principle of 'real income' and the procedural requirements of filing a claim were not explicitly decided on merits.

The High Court dismissed the appeals filed by the Revenue. The Court held that the Assessing Officer had not proceeded on the basis of the show-cause notice achieving finality but had put the assessee on notice regarding its contents and elicited a response. However, the Court found that the Assessing Officer had done little else beyond confronting the assessee with the show-cause notice and statements collected by the Excise Department. The Court noted that these statements and their veracity were not independently established by the Assessing Officer. The Court concluded that the Assessing Officer did not have sufficient independent material to make the additions, as the excise show-cause notices were still pending adjudication and the material collected by the Excise Department was yet to be verified. Therefore, the basis for making additions was lacking, rendering the question of the percentage of sales for additions redundant. The Court dismissed all the Tax Appeals.

The High Court dismissed the appeals filed by the Revenue. The Court held that the Assessing Officer had not proceeded on the basis of the show-cause notice achieving finality but had put the assessee on notice regarding its contents and elicited a response. However, the Court found that the Assessing Officer had done little else beyond confronting the assessee with the show-cause notice and statements collected by the Excise Department. The Court noted that these statements and their veracity were not independently established by the Assessing Officer. The Court concluded that the Assessing Officer did not have sufficient independent material to make the additions, as the excise show-cause notices were still pending adjudication and the material collected by the Excise Department was yet to be verified. Therefore, the basis for making additions was lacking, rendering the question of the percentage of sales for additions redundant. The Court dismissed all the Tax Appeals.

The High Court dismissed the appeals filed by the Revenue. The Court held that the Assessing Officer had not proceeded on the basis of the show-cause notice achieving finality but had put the assessee on notice regarding its contents and elicited a response. However, the Court found that the Assessing Officer had done little else beyond confronting the assessee with the show-cause notice and statements collected by the Excise Department. The Court noted that these statements and their veracity were not independently established by the Assessing Officer. The Court concluded that the Assessing Officer did not have sufficient independent material to make the additions, as the excise show-cause notices were still pending adjudication and the material collected by the Excise Department was yet to be verified. Therefore, the basis for making additions was lacking, rendering the question of the percentage of sales for additions redundant. The Court dismissed all the Tax Appeals.

The High Court dismissed the appeals filed by the Revenue. The Court held that the Assessing Officer had not proceeded on the basis of the show-cause notice achieving finality but had put the assessee on notice regarding its contents and elicited a response. However, the Court found that the Assessing Officer had done little else beyond confronting the assessee with the show-cause notice and statements collected by the Excise Department. The Court noted that these statements and their veracity were not independently established by the Assessing Officer. The Court concluded that the Assessing Officer did not have sufficient independent material to make the additions, as the excise show-cause notices were still pending adjudication and the material collected by the Excise Department was yet to be verified. Therefore, the basis for making additions was lacking, rendering the question of the percentage of sales for additions redundant. The Court dismissed all the Tax Appeals.

The High Court noted that the Income Tax Appellate Tribunal (ITAT) had relied on its orders for earlier assessment years when deciding the present matter. The learned counsel for the Revenue candidly admitted that the Revenue's appeals against the ITAT's orders for earlier years, specifically Tax Appeals No. 1035 of 2014 and 1036 of 2014, concerning this very assessee, were dismissed by the High Court on October 7, 2014. Given this precedent and the admission by the Revenue's counsel, the High Court found no reason to interfere. The principle applied is that consistent findings on similar issues for earlier years, especially when upheld by the High Court, should be followed. The operative direction was to dismiss the present Tax Appeal. No issues were expressly left undecided.

The High Court held that the entire issue was based on factual considerations. The Tribunal had extensively discussed the assessee's explanation that her business involved booking air tickets, with commissions paid through banking channels, and that the papers found during the survey represented receivables from customers and not cash transactions. The Tribunal accepted this explanation, substantially endorsing the view of the CIT(A). Since the CIT(A) and the Tribunal reached a definite conclusion based on the materials on record, the High Court found no question of law arising. Regarding the deletion of Rs. 36.50 Lakhs, the CIT(A) had concluded that this amount was already added in an earlier year and could not be added a second time. Consequently, the High Court dismissed the Tax Appeals filed by the Revenue.

The High Court held that the entire issue was based on factual considerations. The Tribunal had extensively discussed the assessee's explanation that her business involved booking air tickets, with commissions paid through banking channels, and that the papers found during the survey represented receivables from customers and not cash transactions. The Tribunal accepted this explanation, substantially endorsing the view of the CIT(A). Since the CIT(A) and the Tribunal reached a definite conclusion based on the materials on record, the High Court found no question of law arising. Regarding the deletion of Rs. 36.50 Lakhs, the CIT(A) had concluded that this amount was already added in an earlier year and could not be added a second time. Consequently, the High Court dismissed the Tax Appeals filed by the Revenue.

The High Court dismissed the Revenue's appeals. The Court noted that a similar issue had previously come before the same High Court in the case of Principal Commissioner of Income-Tax v. Shri Mahila Sewa Sahakari Bank Limited, reported in [2017] 395 ITR 324 (Guj.). In that case, a Division Bench had dismissed the Revenue's appeal with a detailed judgment. Following this precedent, the High Court held that no question of law arose in the present appeals. Therefore, all the Tax Appeals were dismissed. The operative direction was the dismissal of the appeals.

The High Court dismissed the Revenue's appeals. The Court noted that a similar issue had previously come before the same High Court in the case of Principal Commissioner of Income-Tax v. Shri Mahila Sewa Sahakari Bank Limited, reported in [2017] 395 ITR 324 (Guj.). In that case, a Division Bench had dismissed the Revenue's appeal with a detailed judgment. Following this precedent, the High Court held that no question of law arose in the present appeals. Therefore, all the Tax Appeals were dismissed. The operative direction was the dismissal of the appeals.

The High Court dismissed the Revenue's appeals. The Court noted that a similar issue had previously come before the same High Court in the case of Principal Commissioner of Income-Tax v. Shri Mahila Sewa Sahakari Bank Limited, reported in [2017] 395 ITR 324 (Guj.). In that case, a Division Bench had dismissed the Revenue's appeal with a detailed judgment. Following this precedent, the High Court held that no question of law arose in the present appeals. Therefore, all the Tax Appeals were dismissed. The operative direction was the dismissal of the appeals.

The High Court dismissed the Revenue's appeals. The Court noted that a similar issue had previously come before the same High Court in the case of Principal Commissioner of Income-Tax v. Shri Mahila Sewa Sahakari Bank Limited, reported in [2017] 395 ITR 324 (Guj.). In that case, a Division Bench had dismissed the Revenue's appeal with a detailed judgment. Following this precedent, the High Court held that no question of law arose in the present appeals. Therefore, all the Tax Appeals were dismissed. The operative direction was the dismissal of the appeals.

The High Court granted permission to the Revenue to withdraw the appeals. The reasoning provided is that the tax effect in these appeals is 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. Consequently, the Tax Appeals were disposed of as withdrawn. The specific findings on the merits of the original assessment or appeals are not discussed as the appeals were withdrawn. No issues were left undecided, as the appeals were disposed of on a procedural ground.

The High Court granted permission to the Revenue to withdraw the appeals. The reasoning provided is that the tax effect in these appeals is 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. Consequently, the Tax Appeals were disposed of as withdrawn. The specific findings on the merits of the original assessment or appeals are not discussed as the appeals were withdrawn. No issues were left undecided, as the appeals were disposed of on a procedural ground.

The High Court granted permission to the revenue to withdraw the appeals. The reasoning was based on the CBDT circular dated 11.07.2018, which sets a minimum threshold for the tax effect for the department to prefer and maintain appeals before the High Court. As the tax effect in these appeals was below this prescribed limit, the court allowed the withdrawal. The appeals were disposed of accordingly. No specific findings were made on the merits of the original dispute, as the appeals were withdrawn before any such adjudication.

The High Court granted permission to the Revenue 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 circular dated 11.07.2018. This circular provides guidelines for the department regarding the monetary limits for preferring and maintaining appeals before the High Court. As the condition for maintaining appeals based on tax effect was not met, the Court allowed the withdrawal. The appeals are disposed of accordingly.

The High Court granted permission to the Revenue 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 circular dated 11.07.2018. This circular provides guidelines for the department regarding the monetary limits for preferring and maintaining appeals before the High Court. As the condition for maintaining appeals based on tax effect was not met, the Court allowed the withdrawal. The appeals are disposed of accordingly.

The High Court granted permission to the Revenue 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 circular dated 11.07.2018. This circular guides the department on when to prefer and maintain appeals before the High Court. Consequently, the Tax Appeals were disposed of as withdrawn.

The High Court granted permission to the Revenue to withdraw the appeals. The reasoning provided is 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 governs the conditions under which the department can file and continue appeals before the High Court. Consequently, the appeals were disposed of as withdrawn. No specific findings were made on the merits of the original tax disputes, as the appeals were withdrawn based on administrative guidelines regarding monetary limits.

The High Court granted permission to the Revenue 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 circular dated 11.07.2018. This circular provides guidelines for the department regarding the monetary limits for preferring and maintaining appeals before the High Court. As the condition for maintaining appeals based on tax effect was not met, the Court allowed the withdrawal. The appeals are disposed of accordingly.

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 stipulated by the CBDT's circular dated July 11, 2018. This circular provides guidelines for the department regarding the monetary limits for filing and pursuing appeals before higher judicial forums. Since the condition for maintaining the appeal as per the circular was not met, the Court allowed the withdrawal. The appeals were disposed of accordingly. No specific issue was decided on merits.

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 stipulated by the CBDT circular dated 11.07.2018. This circular provides guidelines for the department regarding the monetary limits for filing and pursuing appeals. Since the condition for maintaining appeals as per the circular was not met, the Court allowed the withdrawal. The appeals were disposed of accordingly. No specific issue was decided on merits.

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 July 11, 2018. This circular dictates the criteria for the department to file and pursue appeals before the High Court. Consequently, the appeals were disposed of as withdrawn. The High Court did not decide on the merits of any of the underlying tax disputes. The operative direction was to dispose of the appeals as withdrawn.

The High Court granted permission to the revenue to withdraw the appeals. The Court noted that the learned advocate for the department, under instructions, sought permission to withdraw these appeals. The reason provided was that the tax effect involved in these appeals was below the minimum threshold limit set by the CBDT in its circular dated 11.07.2018, which specifies the conditions under which the department can 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 the appeals.

The High Court granted permission to the Revenue to withdraw the appeals. The Court reasoned that the Revenue's submission regarding the tax effect being below the threshold limit stipulated in the CBDT circular dated 11.07.2018 was accepted. This circular sets the minimum monetary limit for filing and pursuing appeals by the department. Since the condition for maintainability of appeals, 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 finding was given on the merits of the original assessment or any prior appellate orders.