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512 orders · Page 6 of 11
The High Court held that the Tax Appeal was not pressed by the Revenue due to the low tax effect, in accordance with Circular No. 17/2019 dated August 8, 2019. The Court noted the monetary limits stipulated in the circular, specifically that appeals before the High Court are subject to a limit of Rs. 1,00,00,000. Based on this, the Court disposed of the appeal. The principle derived is that appeals with a low tax effect, falling below the limits prescribed by CBDT circulars, may not be pursued. The Revenue was granted liberty to revive the Tax Appeal in case of any difficulty. No specific issue was left undecided; the appeal was disposed of on procedural grounds.
The High Court decided to dispose of the tax appeal. The reasoning was based on the Circular No. 17/2019, dated 8th August 2019, which establishes monetary limits for appeals. For appeals before the High Court, the monetary limit is Rs. 1,00,000. Since the appeal was notified due to a low tax effect, and the revenue did not press the appeal in view of this circular, the court disposed of the appeal accordingly. The ratio decidendi is that appeals with a tax effect below the prescribed monetary limit in the relevant circular should be withdrawn or not pressed. The operative direction was to dispose of the appeal. The court also reserved liberty for the Revenue to revive the tax appeal in case of any difficulty.
The High Court held that the tax appeal was not pressed by the appellant (Revenue) due to the low tax effect, as per Circular No. 17/2019 dated August 8, 2019. The court acknowledged the revised monetary limits for appeals stipulated in the circular, which indicated that appeals with a tax effect below Rs. 1,00,00,000 before the High Court were to be considered for disposal on this ground. Consequently, the appeal was disposed of in accordance with the policy outlined in the circular. The court also reserved the liberty for the Revenue to revive the tax appeal in case of any difficulty. No specific finding was made on the merits of the original dispute.
The High Court held that the Tax Appeal was not pressed by the Revenue in view of the low tax effect, considering Circular No. 17/2019 dated August 8, 2019. This circular prescribes monetary limits for filing appeals before various authorities, with a limit of Rs. 1,00,00,000 before the High Court. The Court disposed of the appeal accordingly. The reasoning was based on the policy decision of the government to restrict appeals with low tax effect. The ratio decidendi is that appeals with a tax effect below the prescribed monetary limits, as per CBDT circulars, are not to be pressed. The operative direction was to dispose of the appeal. The Court reserved liberty for the Revenue to revive the appeal in case of any difficulty.
The Tribunal decided that the Tax Appeal was not pressed by the Revenue in view of the low tax effect, as per Circular No. 17/2019 dated August 8, 2019. The circular establishes monetary limits for appeals, with appeals before the High Court having a limit of Rs. 1,00,00,000. The court disposed of the appeal accordingly. The judgment also reserves liberty for the Revenue to revive the Tax Appeal in case of any difficulty. No specific issue was left undecided; the appeal was disposed of based on the stated circular and the Revenue's decision not to press it.
The High Court held that the appeal is not pressed and is disposed of in view of the low tax effect, as per Circular No. 17/2019 dated August 8, 2019. The court noted the monetary limits prescribed by the circular for appeals before the High Court (Rs. 1,00,00,000). The reasoning is that the appeal falls within the scope of the circular, which guides the Revenue's decision to withdraw or not press appeals with a low tax effect. The ratio decidendi is that appeals below the prescribed monetary threshold, as per CBDT circulars, are to be disposed of without detailed adjudication on merits. The operative direction is the disposal of the appeal, with liberty reserved for the Revenue to revive the tax appeal in case of any difficulty.
The High Court held that the Tax Appeal was not pressed by the Revenue in view of the low tax effect, having regard to Circular No. 17/2019, dated 8th August, 2019. The Court noted the revised monetary limits for appeals as per the circular, which sets a limit of ₹1,00,00,000 for appeals before the High Court. The reasoning is that the appeal falls within the scope of the circular, which mandates disposal based on low tax effect. The operative direction was to dispose of the appeal accordingly. The Court also reserved liberty for the Revenue to revive the tax appeal in case of any difficulty. No specific issue was left undecided; the appeal was disposed of on procedural grounds related to the circular.
The High Court decided to dispose of the tax appeal in accordance with Circular No. 17/2019 due to the low tax effect. The Court noted that the appeal was not pressed by the Revenue based on this circular. The reasoning is that the monetary limit for appeals before the High Court, as stipulated in the circular, was not met, making it undesirable for the Revenue to pursue the appeal. The operative direction is that the appeal is disposed of. The Court also reserved liberty for the Revenue to revive the tax appeal in case of any difficulty. No specific issue was left undecided; the appeal was disposed of on procedural grounds related to the circular.
The Tribunal decided that the appeal should be disposed of in accordance with Circular No. 17/2019 due to the low tax effect. The reasoning is that the appeal falls within the monetary limits prescribed by the circular for not being pressed. The ratio is that appeals with a low tax effect, as defined by the CBDT circulars, are to be withdrawn or not pressed. The operative direction is that the appeal is disposed of accordingly. The Revenue is granted liberty to revive the tax appeal in case of any difficulty. No issue was expressly left undecided.
The High Court held that the appeal is disposed of in accordance with Circular No. 17/2019, dated August 8, 2019, due to the low tax effect. The Court noted the monetary limits specified in the circular for appeals before the High Court. The appeal was not pressed by the Revenue. The Court reserved the liberty for the Revenue to revive the tax appeal in case of any difficulty. No specific findings on the merits of the case were made as the appeal was not pressed.
The High Court held that the Tax Appeal was not pressed by the Revenue in view of the low tax effect and the policy decision reflected in Circular No. 17/2019. The Court noted the monetary limits for appeals before the High Court as Rs. 1,00,00,000 as per the circular. Consequently, the appeal was disposed of in accordance with the circular. The Court also reserved the liberty for the Revenue to revive the tax appeal in case of any difficulty. No specific issue was decided on merits.
The High Court held that the appeal was not pressed in view of the low tax effect, as per Circular No. 17/2019 dated August 8, 2019. The court disposed of the appeal accordingly. The court also reserved the liberty for the Revenue to revive the tax appeal in case of any difficulty. The specific tax effect or the amount in dispute was not recorded. The judgment does not provide any reasoning on the merits of the original dispute, as the appeal was disposed of on procedural grounds related to the tax effect policy.
The High Court held that the appeal is not pressed by the appellant (Revenue) in view of the low tax effect and the policy outlined in Circular No. 17/2019. The circular specifies that appeals before the High Court should not be filed if the tax effect is below Rs. 1,00,00,000. Consequently, the appeal was disposed of in accordance with this circular. The court reserved liberty for the Revenue to revive the tax appeal in case of any difficulty. No specific finding was made on the merits of the original dispute.
The High Court held that the Tax Appeal was not pressed by the Revenue in view of the low tax effect and the policy decision reflected in Circular No. 17/2019. The circular establishes monetary limits for appeals, with appeals before the High Court having a limit of Rs. 1,00,00,000. Since the appeal was not pressed due to the low tax effect, the Court disposed of the appeal accordingly. The reasoning is based on the administrative policy of the Revenue to withdraw or not press appeals below certain monetary thresholds to streamline litigation. The ratio is that appeals can be disposed of without merits if the appellant (Revenue) chooses not to press them due to administrative policy, such as low tax effect. The operative direction was to dispose of the appeal, with liberty reserved for the Revenue to revive it if any difficulty arises.
The High Court held that the Tax Appeal is not pressed by the Revenue in view of the low tax effect, as per Circular No. 17/2019 dated 8th August, 2019. The Court noted the monetary limits specified in the circular for appeals before the Appellate Tribunal (Rs. 50,00,000), High Court (Rs. 1,00,00,000), and Supreme Court (Rs. 2,00,00,000). Since the tax effect in this appeal was below the limit for High Court appeals, it was not pressed. The appeal was disposed of accordingly. The Revenue was granted liberty to revive the tax appeal in case of any difficulty. No specific finding was given on the merits of the original dispute.
The High Court noted that the appeal was not pressed by the Revenue due to the low tax effect, in accordance with Circular No. 17/2019. This circular establishes revised monetary limits for appeals, with appeals before the High Court having a monetary limit of Rs. 1,00,00,000. Given that the appeal was not pressed and the policy outlined in the circular, the Court disposed of the tax appeal accordingly. The Revenue was granted liberty to revive the tax appeal in case of any difficulty. No specific finding was made on the merits of the original dispute.
The High Court held that the Tax Appeal should be disposed of in view of Circular No. 17/2019 dated August 8, 2019, and the low tax effect. The appeal was not pressed by the appellant (Revenue) in accordance with the new policy reflected in the circular. The court noted the monetary limit for appeals before the High Court as Rs. 1,00,00,000. The appeal was disposed of accordingly. The court also granted liberty to the Revenue to revive the tax appeal in case of any difficulty. No specific issue was left undecided, as the appeal was not pressed on merits.
The High Court held that the tax appeal was not pressed by the Revenue in view of the low tax effect, as per Circular No. 17/2019. The Court noted the new policy reflected in the circular, which sets monetary limits for appeals. Specifically, appeals before the High Court have a monetary limit of Rs. 1,00,00,000. Consequently, the appeal was disposed of accordingly. The Court reserved liberty for the Revenue to revive the tax appeal in case of any difficulty. The ratio is that appeals with a low tax effect, falling below the prescribed monetary limits in relevant circulars, are not to be pressed, leading to their disposal.
The High Court held that the Tax Appeal was not pressed by the Revenue in view of the low tax effect, as per Circular No. 17/2019 dated August 8, 2019. The circular establishes revised monetary limits for appeals, with Rs. 1,00,00,000 being the limit for appeals before the High Court. Consequently, the appeal was disposed of in accordance with this policy. The court granted the Revenue liberty to revive the tax appeal in case of any difficulty. No specific finding was made on the merits of the original dispute, as the appeal was decided on procedural grounds related to the tax effect and departmental policy.
The High Court decided to dispose of the tax appeal. The primary reason for this decision was the low tax effect, as guided by Circular No. 17/2019. The Court acknowledged that the appeal was not pressed by the appellant (Revenue) in light of this circular and the updated monetary limits for appeals. The Court explicitly stated that the appeal is disposed of accordingly. Furthermore, the Court reserved the liberty for the Revenue to revive the tax appeal in case of any difficulty. No specific findings were made on the merits of the original dispute, as the appeal was decided on procedural grounds related to the tax effect policy.
The High Court of Gujarat at Ahmedabad decided to dispose of the tax appeal. The decision was based on the Revenue's submission that the appeal was not pressed due to a low tax effect, in accordance with Circular No. 17/2019. This circular establishes monetary limits for appeals, with Rs. 1,00,00,000 being the limit for appeals before the High Court. The Court noted that the appeal was being disposed of in view of this circular and the low tax effect. The Revenue was granted liberty to revive the tax appeal in case of any difficulty. No specific finding was made on the merits of the original dispute.
The High Court noted that the appeal was notified for an appropriate order due to low tax effect, as per Circular No. 17/2019. The Revenue stated that the appeal was not pressed in view of this circular and the monetary limits prescribed therein. The court acknowledged the new policy reflected in the circular, which sets a monetary limit of Rs. 1,00,00,000 for appeals before the High Court. Consequently, the appeal was disposed of accordingly. The court reserved liberty for the Revenue to revive the tax appeal in case of any difficulty.
The High Court held that the appeal is not pressed by the Revenue in view of the low tax effect and the policy outlined in Circular No. 17/2019. The circular establishes monetary limits for appeals, with appeals before the High Court having a limit of Rs. 1,00,00,000. Consequently, the appeal was disposed of accordingly. The court reserved the liberty for the Revenue to revive the tax appeal in case of any difficulty. No specific findings on the merits of the original assessment or the grounds of appeal were made, as the appeal was not pressed.
The High Court held that the Tax Appeal is not pressed by the Revenue in view of the low tax effect, citing Circular No. 17/2019 dated 8th August, 2019. The Court noted the monetary limits prescribed by the Circular for appeals before the Income Tax Appellate Tribunal (Rs. 50,00,000), High Court (Rs. 1,00,00,000), and Supreme Court (Rs. 2,00,00,000). Consequently, the appeal was disposed of accordingly. The Court reserved liberty for the Revenue to revive the tax appeal in case of any difficulty. The specific issue decided was the maintainability and continuation of the appeal based on the updated policy on monetary limits for appeals.
The High Court held that the Tax Appeal was not pressed by the Revenue in view of the low tax effect, having regard to Circular No. 17/2019 dated August 8, 2019. This circular provides monetary limits for filing appeals, with appeals before the High Court having a limit of Rs. 1,00,00,000. The Court disposed of the appeal in accordance with this circular. The reasoning is based on the Revenue's policy decision to withdraw appeals below certain monetary thresholds. The ratio decidendi is that appeals with low tax effect, as defined by CBDT circulars, are not to be pursued. The operative direction was to dispose of the appeal accordingly, with liberty reserved for the Revenue to revive the appeal if any difficulty arose. No specific issue was left undecided.
The High Court of Gujarat at Ahmedabad disposed of the Tax Appeal. The Court noted that the appeal was not pressed by the Revenue in view of the low tax effect, as per Circular No. 17/2019. This circular establishes monetary limits for appeals, with a limit of Rs. 1,00,00,000 for appeals before the High Court. The Court followed the policy outlined in the circular and disposed of the appeal accordingly. The Revenue was granted liberty to revive the Tax Appeal in case of any difficulty. The specific findings on the merits of the original dispute before the Tribunal are not recorded as the appeal was not pressed.
The High Court held that the Tax Appeal was not pressed by the Revenue due to the low tax effect, in accordance with Circular No. 17/2019 dated August 8, 2019. This circular establishes monetary limits for appeals, with appeals before the High Court having a limit of Rs. 1,00,00,000. The Court disposed of the appeal accordingly. The Revenue was granted liberty to revive the Tax Appeal in case of any difficulty. The specific tax effect or the assessment year(s) are not recorded in the judgment.
The High Court noted that the appeal was not pressed by the Revenue due to the low tax effect, in accordance with Circular No. 17/2019. This circular establishes revised monetary limits for appeals, with a limit of Rs. 1,00,000 for appeals before the High Court. The Court observed that the appeal was to be disposed of in light of this policy. Consequently, the appeal was disposed of. The Court also reserved the liberty for the Revenue to revive the tax appeal in case of any difficulty. No specific finding on the merits of the original dispute was made as the appeal was not pressed.
The High Court held that the appeal is not pressed by the Revenue in view of the low tax effect, as per Circular No. 17/2019. The Court noted the new policy regarding monetary limits for appeals, stating that appeals before the High Court have a limit of Rs. 1,00,00,000. Consequently, the appeal was disposed of accordingly. The Court also reserved the liberty for the Revenue to revive the tax appeal in case of any difficulty. No specific finding was made on the merits of the original dispute, as the appeal was not pressed.
The High Court held that the appeal should be disposed of in view of the low tax effect, as per Circular No. 17/2019. The Revenue explicitly stated that the appeal was not pressed. The Court noted the circular's revised monetary limits for appeals, indicating that appeals with a tax effect below certain thresholds are not to be pursued. The operative direction was to dispose of the appeal accordingly. The Court also reserved liberty for the Revenue to revive the tax appeal in case of any difficulty. No specific issue regarding the merits of the original assessment or the grounds of appeal was decided.
The High Court decided to dispose of the Tax Appeal based on the Revenue's submission that it was not pressed due to a low tax effect. The Court referred to Circular No. 17/2019, dated August 8, 2019, issued by the CBDT, which outlines monetary limits for filing appeals. For appeals before the High Court, the monetary limit is Rs. 1,00,00,000. Since the appeal was deemed to have a low tax effect in light of this circular, it was disposed of accordingly. The Court explicitly reserved the liberty for the Revenue to revive the tax appeal in case of any difficulty. No specific findings on the merits of the original dispute were made, as the appeal was not pressed.
The High Court held that the Tax Appeal was not pressed by the Revenue in view of the low tax effect, as per Circular No. 17/2019 dated August 8, 2019. The circular establishes a monetary limit of Rs. 1,00,00,000 for appeals before the High Court. Consequently, the appeal was disposed of accordingly. The Court also reserved the liberty for the Revenue to revive the tax appeal in case of any difficulty. The principle derived is that appeals below the prescribed monetary threshold, as per the CBDT's policy, may be withdrawn or not pressed by the Revenue, leading to their disposal without a decision on merits.
The High Court held that the tax appeal is not pressed by the Revenue in view of the low tax effect, as per Circular No. 17/2019, dated August 8, 2019. The Court noted the monetary limits for appeals before different authorities as per the circular. Consequently, the appeal was disposed of accordingly. The Revenue was granted liberty to revive the tax appeal in case of any difficulty. The specific tax effect or the assessment year(s) were not recorded in the judgment.
The Tribunal decided that the Tax Appeal is not pressed by the Revenue due to the low tax effect, in accordance with Circular No. 17/2019 dated August 8, 2019. The circular establishes monetary limits for appeals, with appeals before the High Court having a limit of Rs. 1,00,00,000. The High Court noted that the appeal was disposed of in view of the aforesaid circular. The Court reserved the liberty for the Revenue to revive the Tax Appeal in case of any difficulty. No specific issue was decided on merits, and the appeal was disposed of based on the Revenue's decision not to press it.
The Tribunal decided that the appeal should be disposed of in accordance with Circular No. 17/2019 due to the low tax effect. The reasoning was based on the new policy introduced by the Central Board of Direct Taxes, which sets monetary limits for appeals. The appeal was not pressed by the revenue, and the court acknowledged the circular's directive to dispose of such matters. The operative direction was to dispose of the appeal accordingly. The court also granted liberty to the revenue to revive the tax appeal in case of any difficulty. No specific issue was left undecided; the entire appeal was disposed of based on the circular.
The High Court noted that the appeal was listed for passing an appropriate order, specifically because of the low tax effect. The Court referred to Circular No. 17/2019, dated August 8, 2019, which outlines monetary limits for appeals. According to this circular, appeals before the High Court have a monetary limit of Rs. 1,00,00,000. The Court observed that the present appeal was not pressed by the Revenue in view of the low tax effect, aligning with the policy reflected in the aforementioned circular. Consequently, the appeal was disposed of accordingly. The Court also reserved liberty for the Revenue to revive the tax appeal in case of any difficulty.
The High Court of Gujarat at Ahmedabad disposed of the tax appeal. The court noted that the appeal was not pressed by the appellant (Commissioner of Income Tax) in view of the low tax effect, as per Circular No. 17/2019 dated 8th August, 2019. This circular sets monetary limits for appeals, with a limit of Rs. 1,00,00,000 for appeals before the High Court. The court acknowledged the revenue's decision not to pursue the appeal due to this circular. The court reserved the liberty for the Revenue to revive the tax appeal in case of any difficulty. No specific findings on the merits of the original dispute were made as the appeal was disposed of on procedural grounds related to the tax effect.
The High Court decided to dispose of the appeal in accordance with CBDT Circular No. 17/2019, dated August 8, 2019. The Court noted that the appeal was not pressed by the Revenue due to its low tax effect. The circular establishes a monetary limit of Rs. 1,00,00,000 for appeals to be filed before the High Court. Since the tax effect in this appeal was below this limit, the appeal was disposed of accordingly. The Court explicitly reserved the liberty for the Revenue to revive the tax appeal in case of any difficulty. No specific findings were made on the merits of the original assessment or appeal.
The High Court decided that the appeal should be disposed of in accordance with Circular No. 17/2019 due to the low tax effect. The Revenue stated that the appeal was not pressed. The Court noted the monetary limits specified in the circular, with appeals before the High Court having a limit of Rs. 1,00,00,000. The appeal was disposed of based on this policy. The Court also granted liberty to the Revenue to revive the tax appeal if any difficulty arises. No specific issue regarding the merits of the original assessment or the order under challenge was decided.
The High Court held that the tax appeal is not pressed in view of the low tax effect and Circular No. 17/2019. The court disposed of the appeal accordingly. The reasoning is based on the new policy reflected in the circular, which establishes monetary limits for appeals. Since the appeal falls within the category of low tax effect, it is not being pursued. The court granted liberty to the Revenue to revive the tax appeal in case of any difficulty. No specific finding was made on the merits of the original dispute.
The High Court of Gujarat at Ahmedabad decided to dispose of the tax appeal. The Court acknowledged that the appeal was not pressed by the appellant (Revenue) due to the low tax effect, referencing Circular No. 17/2019. This circular sets a monetary limit of Rs. 1,00,000 for appeals before the High Court. Consequently, the appeal was disposed of in accordance with this policy. The Court also reserved the liberty for the Revenue to revive the tax appeal in case of any difficulty. No specific finding was made on the merits of the original dispute, as the disposal was based on procedural and policy grounds.
The High Court held that the tax appeal is disposed of in view of the low tax effect and the policy outlined in Circular No. 17/2019. The Revenue had explicitly stated that the appeal was not pressed on this ground. The court accepted this position and disposed of the appeal accordingly. The court also reserved liberty for the Revenue to revive the tax appeal in case of any difficulty. No specific finding was made on the merits of the original dispute, as the appeal was not pressed. The ratio decidendi is that appeals below the prescribed monetary limits, as per CBDT circulars, are to be withdrawn or not pressed, leading to their disposal without adjudication on merits.
The High Court held that the appeal is not pressed by the Revenue in view of the low tax effect, as per Circular No. 17/2019. The circular establishes a monetary limit of Rs. 1,00,00,000 for appeals before the High Court. Consequently, the appeal was disposed of in accordance with this policy. The Court also granted liberty to the Revenue to revive the tax appeal if any difficulty arises. No specific finding on the merits of the original dispute was made, as the appeal was not pressed.
The High Court noted that the captioned appeal was notified for passing an appropriate order due to its low tax effect. The Court referred to Circular No. 17/2019, dated August 8, 2019, which sets monetary limits for appeals. The Court observed that the appeal was not pressed by the Revenue in view of the low tax effect, as per the new policy reflected in the circular. The monetary limits stipulated in the circular for appeals before the High Court are Rs. 1,00,00,000. The Court disposed of the appeal accordingly, reserving liberty for the Revenue to revive it in case of any difficulty. No specific finding on the merits of the original assessment or the order under challenge was made.
The High Court held that the Tax Appeal was not pressed by the appellant (Principal Commissioner of Income Tax-5) in view of the low tax effect. The Court referred to Circular No. 17/2019, dated August 8, 2019, issued by the Government of India, Ministry of Finance, Department of Revenue, Central Board of Direct Taxes. This circular outlines monetary limits for appeals, with appeals before the High Court having a limit of Rs. 1,00,00,000. Since the appeal was not pressed due to the low tax effect, it was disposed of accordingly. The Court also reserved the liberty for the Revenue to revive the tax appeal in case of any difficulty. No decision on the merits of the original assessment or appeal was made.
The High Court noted that the appeal was notified for passing an appropriate order due to low tax effect, in accordance with Circular No. 17/2019. The Court observed that the appeal was not pressed by the Revenue in view of the low tax effect and the revised monetary limits stipulated in the aforementioned circular. The circular sets a monetary limit of Rs. 1,00,00,000 for appeals before the High Court. Since the appeal was not pressed, the Court disposed of the appeal accordingly. The Court also reserved liberty for the Revenue to revive the tax appeal in case of any difficulty.
The High Court held that the tax appeal is not pressed in view of the low tax effect, having regard to Circular No. 17/2019 dated August 8, 2019. This circular introduces new monetary limits for appeals. For appeals before the High Court, the monetary limit is Rs. 1,00,00,000. The appeal was disposed of accordingly. The Court also reserved liberty for the Revenue to revive the tax appeal in case of any difficulty. The specific tax effect or the original dispute amount was not recorded in the judgment.
The High Court held that the Tax Appeal is disposed of in view of the low tax effect, as per Circular No. 17/2019. The Court noted the policy outlined in the circular, which specifies monetary limits for appeals. Specifically, for appeals before the High Court, the monetary limit is Rs. 1,00,00,000. Since the appeal was not pressed by the Revenue due to its low tax effect, the Court decided to dispose of the appeal accordingly. The Court also reserved the liberty for the Revenue to revive the tax appeal in case of any difficulty. The specific tax effect or the assessment year(s) were not recorded in the judgment.
The High Court held that the appeal was not pressed by the appellant (Revenue) in view of the low tax effect, as per Circular No. 17/2019. The circular specifies that appeals before the High Court should not be filed if the tax effect is below Rs. 1,00,00,000. Consequently, the appeal was disposed of accordingly. The court also reserved the liberty for the Revenue to revive the tax appeal in case of any difficulty. No specific finding was made on the merits of the original dispute, as the appeal was decided on procedural grounds related to the tax effect policy.
The High Court of Gujarat held that the appeal was not pressed by the Revenue. This decision was based on Circular No. 17/2019, dated August 8, 2019, which established revised monetary limits for filing appeals. The Court noted that the appeal was notified for disposal due to a low tax effect. The operative direction was to dispose of the appeal accordingly. The Court also reserved liberty for the Revenue to revive the tax appeal in case of any difficulty. The specific finding on the merits of the original tax dispute is not recorded as the appeal was not pressed.