Gujarat High Court Judgments — 2018

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 in its circular dated 11.07.2018. This circular guides the department on when it is permissible to 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 Consequently, the appeals were disposed of as withdrawn.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 dispute between the assessee and the Revenue.

The High Court granted permission to the Revenue to withdraw the appeals. The reasoning provided was 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 only when the tax effect meets the specified criteria. Since the present appeals did not meet this criterion, the court allowed the withdrawal. The operative direction was to dispose of the Tax Appeals accordingly, meaning they were dismissed as withdrawn. No specific issues regarding the merits of the original assessment or appeals were decided.

The High Court granted permission to the Revenue to withdraw the appeals. The reasoning provided was 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 only when the tax effect meets the specified criteria. Since the present appeals did not meet this criterion, the court allowed the withdrawal. The operative direction was to dispose of the Tax Appeals accordingly, meaning they were dismissed as withdrawn. No specific issues regarding the merits of the original assessment or appeals were decided.

The High Court granted permission to the Revenue to withdraw the appeals. The reasoning provided was 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 only when the tax effect meets the specified criteria. Since the present appeals did not meet this criterion, the court allowed the withdrawal. The operative direction was to dispose of the Tax Appeals accordingly, meaning they were dismissed as withdrawn. No specific issues regarding the merits of the original assessment or appeals were decided.

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 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 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 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 each of these appeals was below this stipulated limit, 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, as the appeals were withdrawn before any such adjudication.

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 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 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 was that the tax effect in these appeals fell below the minimum threshold limit stipulated in the CBDT circular dated 11.07.2018. This circular permits the department to withdraw or not pursue appeals where the tax effect is below a certain monetary limit. 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 procedurally.

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 the permission sought by the Revenue to withdraw the appeals. The reasoning behind this decision is that the tax effect in these appeals was below the minimum threshold limit prescribed by the CBDT circular dated 11.07.2018. This circular dictates the conditions under which the department can file and pursue appeals before the High Court. Consequently, the appeals were disposed of as withdrawn. The specific findings on the merits of the original appeals are not discussed, as the appeals were withdrawn based on a procedural ground related to the tax effect and the departmental policy as outlined in the circular. No issues were expressly left undecided, as the appeals were disposed of without a decision on the merits.

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 was based on the Revenue's submission that the tax effect 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. Since the condition stipulated in the circular was met for withdrawal, the Court allowed the request. The appeals were disposed of accordingly. No specific findings were made on the merits of the original disputes, as the appeals were 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 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. Since the condition stipulated in the circular was met for withdrawal, the Court allowed the request. The appeals were disposed of accordingly. No specific findings were made on the merits of the original disputes, as the appeals were withdrawn by the Revenue.

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 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 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 Court's decision was based on the explicit request made by the learned advocate for the Revenue, Ms. Mauna Bhatt, who stated that she had instructions from the department to withdraw the appeals. The reason provided for this withdrawal was 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 permits the department to refrain from preferring and maintaining appeals before the High Court when the tax effect is below the specified limit. The Court found this reason sufficient and disposed of the Tax Appeals accordingly. No other issues were decided on merits, and no specific findings were recorded regarding the substantive tax disputes.

The High Court, in its judgment dated May 6, 2022, ultimately dismissed all the Letters Patent Appeals and the connected writ-applications. The Court found no reason to interfere with the decisions of the learned Single Judge. Regarding the specific cases: - For IOC, the Court noted that while renewal applications for plots with unexpired leases could be considered, no direction could be issued for plots whose leases had already expired. - For the Tankers' Association, the absence of a renewal clause and expiry of the lease meant renewal was not a right. - For Laxmi Motors, eviction proceedings were already underway, making renewal irrelevant. - For IFFCO, the Government of India's refusal to renew the lease, coupled with the inability to charge commercial rates, meant KPT was justified in not renewing. - For Kesar Terminals and Infra. Limited, illegal transfers post-lease expiry led to eviction proceedings, precluding renewal. - For AVEAN International Pvt. Ltd., the KPT's policy decision to use public auction for allotments, in line with its land policies, was upheld, and the reliance on Clause 5.2.1.2 was rejected as the lease deed did not provide for renewal. The ratio decidendi is that lease renewal is not an absolute right, especially after expiry, and port authorities can adopt policies like public auction for land allotment, provided such policies are consistent with law and their governing statutes. The Court agreed with the Single Judge's conclusion that no direction for renewal could be issued in these circumstances.

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 provides guidelines for the minimum tax effect required to file and pursue appeals before the High Court. Since the tax effect in these appeals was below the stipulated threshold, the Court allowed the withdrawal. The appeals were disposed of accordingly. No specific findings were made on the merits of the original disputes, and no issue was left undecided as the appeals were withdrawn by the appellant.

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 circular dated 11.07.2018. This circular provides guidelines for the department regarding the monetary limits for filing and pursuing appeals. By granting permission, the Court acknowledged the department's right to withdraw appeals that no longer meet the prescribed financial criteria for litigation. Consequently, all the Tax Appeals were disposed of as withdrawn, with no decision on the merits of the underlying tax disputes.

The High Court of Gujarat at Ahmedabad, comprising Justices Akil Kureshi and B.N. Karia, granted the Revenue's request to withdraw the appeals. The Court reasoned that the Revenue had sought permission to withdraw based on a CBDT circular dated 11.07.2018, which stipulated a minimum tax effect threshold for filing and maintaining appeals before the High Court. Since the tax effect in these appeals fell below this threshold, the Revenue was entitled to withdraw them. The Court found no impediment to granting this permission. Consequently, all the listed Tax Appeals were disposed of as withdrawn. No specific findings were made on the merits of the original disputes.

The High Court granted permission to the Revenue to withdraw the appeals. The reasoning provided is that the Revenue's representative, acting on instructions, stated that the tax effect in these appeals fell below the threshold limit stipulated by the CBDT's circular dated 11.07.2018. This circular guides the department on when to prefer and maintain appeals before the High Court. Consequently, the appeals were disposed of as withdrawn. No decision was made on the merits of the underlying tax disputes.

The High Court granted permission to the Revenue to withdraw the appeals. The Court reasoned that the withdrawal was sought based on a CBDT circular dated July 11, 2018, which sets a minimum threshold for tax effect for preferring and maintaining appeals. Since the tax effect in these appeals fell below this threshold, the Court allowed the withdrawal. Consequently, all the listed Tax Appeals were disposed of accordingly. No decision on the merits of the appeals was made. The operative direction was to dispose of the appeals as withdrawn.

The High Court of Gujarat disposed of all the captioned writ petitions without adjudicating them on merit. This decision was made in light of the pronouncement of the Apex Court in the case of Union of India and Others vs. Ashish Agarwal. The Apex Court's order, which was made applicable PAN India, provided that notices issued under the unamended Section 148 of the Income Tax Act, 1961, from April 1, 2021, onwards, would be deemed to have been issued under Section 148A of the Act. The assessing officers were directed to provide information to the assessees, who would then have two weeks to reply. Orders under Section 148A(d) were to be passed thereafter, followed by notices under the substituted Section 148. All defenses available to the assessees and the revenue were preserved. The High Court clarified that any other issues not related to Section 148 could be pursued in fresh petitions.

The High Court of Gujarat, in light of the pronouncement of the Apex Court in the case of Union of India and Others vs. Ashish Agarwal, ordered all the captioned writ petitions to be disposed of without any requirement of adjudication on merit. The Apex Court's decision 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 and material relied upon within thirty days, with assessees to reply within two weeks. The requirement of conducting an enquiry 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 defences 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 permission sought by the Revenue to withdraw the appeals. The reasoning provided is that the tax effect in these appeals was below the minimum threshold limit prescribed by the CBDT circular dated 11.07.2018. This circular allows the department to withdraw or not pursue appeals where the tax effect is below a certain limit. Consequently, the High Court disposed of all the Tax Appeals accordingly. No specific finding on the merits of any of the individual appeals was made, as they were withdrawn by the Revenue.

The High Court granted the permission sought by the Revenue to withdraw the appeals. The reasoning provided is that the tax effect in these appeals was below the minimum threshold limit prescribed by the CBDT circular dated 11.07.2018. This circular allows the department to withdraw or not pursue appeals where the tax effect is below a certain limit. Consequently, the High Court disposed of all the Tax Appeals accordingly. No specific finding on the merits of any of the individual appeals was made, as they were withdrawn by the Revenue.

The High Court granted permission to the Revenue to withdraw the appeals. The Court acknowledged the submission made by the learned advocate for the Revenue, Ms. Mauna Bhatt, who stated that the withdrawal was sought under instructions from the department. The reason 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. Consequently, the Court disposed of all the Tax Appeals accordingly, allowing the withdrawal. No specific findings were made on the merits of the original tax disputes.

The High Court granted the permission sought by the Revenue to withdraw the appeals. The reasoning provided is that the tax effect in these appeals was below the minimum threshold limit prescribed by the CBDT circular dated 11.07.2018. This circular allows the department to withdraw or not pursue appeals where the tax effect is below a certain limit. Consequently, the High Court disposed of all the Tax Appeals accordingly. No specific finding on the merits of any of the individual appeals was made, as they were 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 was below the minimum threshold limit prescribed by the CBDT circular dated July 11, 2018. This circular enables the department to refrain from preferring and maintaining appeals before the High Court when the tax effect is insignificant. Consequently, the Tax Appeals were disposed of as withdrawn. No specific finding was made on the merits of the substantive tax issues that might have been raised in the appeals, as the appeals were withdrawn on a procedural ground.

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 prescribed by the CBDT circular dated July 11, 2018. This circular enables the department to refrain from preferring and maintaining appeals before the High Court when the tax effect is insignificant. Consequently, the Tax Appeals were disposed of as withdrawn. No specific finding was made on the merits of the substantive tax issues that might have been raised in the appeals, as the appeals were withdrawn on a procedural ground.

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 prescribed by the CBDT circular dated July 11, 2018. This circular enables the department to refrain from preferring and maintaining appeals before the High Court when the tax effect is insignificant. Consequently, the Tax Appeals were disposed of as withdrawn. No specific finding was made on the merits of the substantive tax issues that might have been raised in the appeals, as the appeals were withdrawn on a procedural ground.

The High Court granted permission to the Revenue to withdraw the appeals. The Court's decision was based on the Revenue's submission that the tax effect in these appeals fell below the minimum threshold limit prescribed by the CBDT circular dated July 11, 2018. This circular empowers the department to withdraw appeals where the tax effect is below a certain amount. The Court found this reason sufficient for allowing the withdrawal. Consequently, all the Tax Appeals were disposed of in terms of the permission granted. 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 request was based on a CBDT circular dated July 11, 2018, which provides guidelines for the department to prefer and maintain appeals before the High Court based on a minimum tax effect. Since the tax effect in these appeals was below the prescribed threshold, 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 the original dispute between the Revenue and the Assessee.

The High Court of Gujarat disposed of all the captioned writ petitions without adjudicating on the merits of the case. This decision was made in light of the Supreme Court's pronouncement in Union of India and Others vs. Ashish Agarwal. The Supreme Court had held that notices issued under the unamended Section 148 of the Income Tax Act, 1961, between April 1, 2021, and June 30, 2021, would be deemed to have been issued under the newly substituted Section 148A of the Act. These would be treated as show-cause notices under Section 148A(b), requiring the Assessing Officer to provide information to the assessees within thirty days and allowing assessees two weeks to reply. The requirement for prior approval for inquiry under Section 148A(a) was dispensed with as a one-time measure. The Assessing Officers were directed to pass orders under Section 148A(d) and then issue notices under the substituted Section 148. All defenses available to the assessees, including those under Section 149, were preserved. The High Court clarified that if any petition contained issues other than those related to Section 148, liberty was reserved to file fresh petitions.

The High Court granted the permission sought by the Revenue to withdraw the appeals. The reasoning provided is that the tax effect in these appeals was below the minimum threshold limit prescribed by the CBDT circular dated 11.07.2018. This circular allows the department to withdraw or not pursue appeals where the tax effect is below a certain limit. Consequently, the High Court disposed of all the Tax Appeals accordingly. No specific finding on the merits of any of the individual appeals was made, as they were withdrawn by the Revenue.

The High Court of Gujarat, in light of the Supreme Court's pronouncement in Union of India and Others vs. Ashish Agarwal, ordered all the captioned writ petitions to be disposed of without adjudication on merit. The Supreme Court's decision held that notices issued under the unamended Section 148 of the Income Tax Act, 1961, which were the subject of writ petitions, shall be deemed to have been issued under Section 148A of the Act as substituted by the Finance Act, 2021. These notices are to be treated as show-cause notices under Section 148A(b). The Assessing Officer is required to provide information and material relied upon within thirty days, allowing assessees two weeks to reply. The requirement of conducting an enquiry with prior approval under Section 148A(a) is dispensed with as a one-time measure for notices issued from April 1, 2021, to date. Subsequently, Assessing Officers are to pass orders under Section 148A(d) and then issue notices under the substituted Section 148. All defenses available to assessees, including those under Section 149, and rights of the Revenue remain preserved. This order is applicable pan-India and governs pending writ petitions.

The High Court granted permission to the Revenue to withdraw the appeals. The Court reasoned that the withdrawal was sought by the department under instructions, citing the CBDT circular dated 11.07.2018. This circular provides a threshold for the tax effect below which appeals should not be preferred or maintained. Since the tax effect in these appeals was below this threshold, the department was enabled to withdraw them. Consequently, the Tax Appeals were disposed of as withdrawn. No specific finding was made on the merits of the original appeals, as they were withdrawn by the appellant.

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 provides guidelines for the department to prefer and maintain appeals before the High Court based on a minimum tax effect. Since the tax effect in these appeals was below the prescribed threshold, 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 the original dispute between the Revenue and the Assessee.

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 prescribed by the CBDT circular dated July 11, 2018. This circular enables the department to refrain from preferring and maintaining appeals before the High Court when the tax effect is insignificant. Consequently, the Tax Appeals were disposed of as withdrawn. No specific finding was made on the merits of the substantive tax issues that might have been raised in the appeals, as the appeals were withdrawn on a procedural ground.

The High Court granted permission to the Revenue to withdraw the appeals. The Court reasoned that the Revenue's request was based on the CBDT Circular dated 11.07.2018, which sets a minimum threshold for the tax effect for filing and pursuing appeals. Since the tax effect in these appeals was below this limit, the Court allowed the withdrawal. The appeals were disposed of accordingly. No specific findings were made on the merits of the underlying tax disputes.

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 stipulated in the CBDT circular dated 11.07.2018. This circular permits the department to withdraw or not prefer appeals where the tax effect is below a certain limit. Consequently, the appeals were disposed of as withdrawn. No specific findings on the merits of the underlying tax disputes were made.

The High Court held that no substantial question of law arises from the order of the ITAT. The Court noted that both the CIT(Appeals) and the Tribunal had minutely examined the materials on record. They had concurrently held that part of the additions made by the Assessing Officer were not sustainable. The Court observed that the issues involved were purely fact-based. Therefore, the Tax Appeal filed by the Revenue was dismissed. The operative direction was the dismissal of the appeal, meaning the ITAT's order stood.

The High Court granted the Revenue's request to withdraw the appeals. The Court reasoned that the Revenue's submission was based on a CBDT circular dated July 11, 2018, which provides a threshold for the tax effect below which appeals need not be preferred or maintained. Since the tax effect in these appeals fell below this minimum threshold, the Revenue was permitted to withdraw them. The Court noted that permission was granted and disposed of the Tax Appeals accordingly. No decision was made on the merits of the substantive tax issues.