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539 orders · Page 8 of 11
The High Court quashed and set aside the impugned notice dated 31.03.2021, issued under Section 148 of the Income Tax Act, 1961. The Court found that the basis for reopening the assessment, as stated in the notice, was factually incorrect. The notice alleged that the assessee deposited Rs. 26,50,000/- in cash into the current account of the partnership firm, Tapas Elegance LLP. However, upon examination of the bank statement, it was revealed that the deposit of Rs. 26,50,000/- was made by the assessee in his individual savings account with Adarsh Co-operative Bank Limited during the financial year 2016-17, relevant to AY 2017-18. The Court also noted that the current account referred to in the AO's order assigning reasons was, in fact, the personal account of the assessee, not that of the partnership firm. The Revenue, represented by learned senior counsel, fairly submitted that a mistake had been committed in issuing the notice. Consequently, the writ application was disposed of with the quashing of the notice.
The High Court held that the writ application filed by the Principal Commissioner of Income Tax is dismissed. The Court found no illegality or infirmity in the impugned order dated March 25, 2021, passed by the ITAT, which rejected the Revenue's Miscellaneous Application. The reasoning was that the ITAT's original order dated August 14, 2019, dismissing the appeal due to low tax effect, was passed before the issuance of CBDT Circular No. 23 of 2019 and the Office Memorandum dated September 16, 2019. These subsequent circulars did not have retrospective effect and did not contemplate application from the date of the earlier circular (August 8, 2019). The ITAT correctly observed that the subsequent circulars would not make the earlier order suffer from an apparent error. The Court relied on observations from a Coordinate Bench in similar matters, which held that the circulars dated September 6, 2019, and September 16, 2019, were not retrospective and that the ITAT had rightly held that the CBDT Circular No. 23/2019 should be read with the Office Memorandum dated 16.09.2019, applying to appeals filed on or after September 16, 2019, pursuant to special orders of the CBDT. Therefore, the ITAT had not committed any mistake apparent from the record requiring rectification under Section 254(2) of the Income Tax Act.
The High Court held that the question of law proposed by the Revenue could not be termed as a substantial question of law, as it was primarily based on factual aspects. The Court noted that the ITAT had recorded specific findings of fact. The ITAT had allowed the appeal and deleted the addition of Rs. 37,13,652/-. The Tribunal's reasoning was that the assessee had provided sufficient evidence to demonstrate the identity of the creditor (Shri Dilip Suthar), the genuineness of the transaction, and his credit-worthiness. The Tribunal found that Shri Dilip Suthar had provided confirmation, PAN, and other details, and crucially, had demonstrated his capacity to provide the funds by purchasing land worth Rs. 2.69 Crores. The Tribunal concluded that the revenue authorities were not justified in disbelieving the assessee's version. The High Court declined to interfere with the ITAT's order. No issue was expressly left undecided.
The High Court held that the impugned assessment order dated April 7, 2021, is invalid and non est. The Court found that the Assessing Officer made variations prejudicial to the assessee by disallowing the deduction under Section 80P(2)(a)(i) and treating it as income from other sources. However, no show cause notice along with a draft assessment order was served upon the writ applicant, thereby denying them an opportunity to explain their position. This non-compliance with the mandatory provisions of Section 144B of the Income Tax Act, particularly Section 144B(1)(xvi)(b), and the principles of natural justice, is fatal to the assessment order. The Court relied on its own decision in Gandhi Reality (India) (P.) Ltd. Vs. Assistant. Consequently, the assessment order and consequential demand notice were quashed and set aside, and the matter was remitted to the Assessing Officer to proceed from the stage of issuing a draft assessment order along with a show cause notice, in accordance with Section 144B of the Act. No issue was expressly left undecided.
The High Court held that the writ application under Article 226 of the Constitution of India was not maintainable. The Court noted that the assessment order passed by the revenue was an appealable order. Therefore, the assessee ought to have availed the statutory remedy of filing an appropriate appeal before the Commissioner of Appeals under Section 251 of the Income Tax Act, 1961. The Court was not convinced with the assessee's submission that the writ jurisdiction should be invoked due to a lack of opportunity of hearing, as this is a matter that can be raised and addressed within the appellate proceedings. Consequently, the writ application was rejected.
The High Court held that the assessment order, being an appealable order, necessitates the filing of an appropriate appeal in accordance with the law before the Commissioner of Appeals, as provided under Section 251 of the Income Tax Act. The Court was not convinced by the assessee's argument that the writ jurisdiction should be invoked due to a lack of opportunity for hearing. Therefore, the writ application was rejected on the grounds that an alternative statutory remedy was available. No decision was made on the merits of the assessment proceedings or the validity of the Section 153C assessment.
The High Court held that the impugned assessment order, being an appealable order, necessitated the assessee availing the statutory alternative remedy of appeal before the Commissioner of Appeals under Section 251 of the Income Tax Act, 1961. The court found that the writ applicant should pursue this appellate route rather than invoking the writ jurisdiction. The court explicitly stated that it had not gone into the merits of the case. The ratio decidendi is that statutory remedies must be exhausted before approaching the writ court for challenging assessment orders that are appealable. The operative direction was to permit the writ applicant to withdraw the application with liberty to file a statutory appeal, allowing all contentions to be raised before the Commissioner of Appeals.
The High Court noted that the appeals were notified due to low tax effect and were to be disposed of in accordance with Circular No. 17/2019. The Revenue explicitly stated that the tax appeal was not pressed in view of the low tax effect, referencing the monetary limits prescribed in the aforementioned circular. The circular stipulates a monetary limit of Rs. 1,00,00,000 for appeals before the High Court. Consequently, the High 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. No specific findings were made on the merits of the original dispute.
The Tribunal decided that the appeal was not pressed by the Revenue in view of the low tax effect, as per Circular No. 17/2019. The reasoning was based on the policy reflected in the said Circular, which establishes monetary limits for appeals. Specifically, for appeals before the High Court, the monetary limit is Rs. 1,00,00,000. Since the appeal had a low tax effect, it was disposed of accordingly. The Court reserved the 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 policy.
The High Court noted that the appeal was not pressed by the appellant (Revenue) in view of the low tax effect, as per Circular No. 17/2019. The Court referred to the table of monetary limits provided in the circular, which specifies limits for appeals before the Appellate Tribunal, High Court, and Supreme Court. In light of the circular and the fact that the appeal was not pressed, the Court disposed of the appeal accordingly. The liberty was reserved 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 disposed of on procedural grounds related to the tax effect policy.
The High Court held that the appeal is not pressed by the Revenue due to the low tax effect, in accordance with Circular No. 17/2019. The Court noted the monetary limit for appeals before the High Court is Rs. 1,00,00,000. Consequently, the appeal was disposed of on this basis. The Court reserved the liberty for the Revenue to revive the tax appeal if any difficulty arises. No decision on the merits of the case was made.
The High Court held that the appeal was not pressed by the Revenue in view of the low tax effect, as per Circular No. 17/2019. The Court noted the monetary limits specified in the circular for appeals before different authorities, including 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. No specific finding was made on the merits of the original tax dispute.
The High Court held that the appeal was not pressed by the Revenue due to the low tax effect, as per Circular No. 17/2019. The Court noted the monetary limit for appeals before the High Court as Rs. 1,00,00,000. 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 arose. 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 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 prescribed by the circular for appeals before various forums, including Rs. 1,00,00,000 for appeals before the High Court. 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 finding was made on the merits of the original dispute, as the appeal was withdrawn based on policy.
The Tribunal held that the appeal was not pressed by the Revenue in view of the low tax effect, as per 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. The Court noted that the appeal was being disposed of in accordance with this policy. The operative direction was to dispose of the appeal accordingly. Liberty was reserved for the Revenue to revive the tax appeal in case of any difficulty. No specific issue was left undecided; rather, the appeal was disposed of on a procedural ground based on a policy circular.
The High Court of Gujarat held that the appeal was not pressed by the Revenue due to its low tax effect, in accordance with Circular No. 17/2019. The circular specifies a monetary limit of Rs. 1,00,00,000 for appeals before the High Court. The Court observed that the appeal was to be disposed of keeping in mind this circular. 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 of Gujarat held that the Tax Appeal is not pressed by the Revenue due to its low tax effect, as per Circular No. 17/2019. The Court noted the monetary limits prescribed by the circular for appeals before the High Court, which is Rs. 1,00,00,000. Consequently, the appeal was disposed of in accordance with this policy. The Court also reserved liberty for the Revenue to revive the appeal in case of any difficulty. The specific tax effect or the substantive grounds of appeal were not decided on merits.
The High Court held 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 a monetary limit of Rs. 1,00,00,000 for appeals to be filed before the High Court. The Court noted the policy reflected 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 tax effect or the assessment year(s) were not recorded in the judgment.
The High Court of Gujarat 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 monetary limits prescribed in the circular for appeals before various authorities, including the High Court (Rs. 1,00,00,000). Consequently, 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 findings were made on the merits of the original assessment or appeal.
The High Court of Gujarat held that the Tax Appeal is not pressed by the Revenue in view of the low tax effect, as per Circular No. 17/2019. The Court noted the monetary limits prescribed by the circular for appeals before the High Court, which is Rs. 1,00,00,000. Consequently, the appeal was disposed of in accordance with this 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, as the appeal was withdrawn by the appellant.
The High Court held that the appeal is not pressed in view of the low tax effect, having regard to Circular No. 17/2019 dated August 8, 2019. The Court noted the monetary limits prescribed by 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). 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 principle is that appeals with low tax effect, as defined by CBDT circulars, can be withdrawn or not pressed by the Revenue.
The High Court noted that the issues raised in the appeal were no longer res integra in light of its own prior judgment in the case of Commissioner of Income-tax Vs. Gujarat State Road Transport Corporation Limited, reported in 366 ITR 170 [Gujarat]. The learned senior counsel for the assessee fairly conceded that the issues were squarely covered by this decision. However, he pointed out that an appeal against the High Court's judgment in the GSRTC case was pending before the Supreme Court, and leave had been granted. The High Court dismissed the present appeal at that stage. It provided a liberty to the appellant to revive the appeal within three months from the date of the Supreme Court's judgment, should the Supreme Court reverse the GSRTC decision. No specific finding was given on the merits of the disallowance, as the appeal was disposed of on procedural grounds pending a higher court's decision.
The High Court noted that the appeals were notified due to low tax effect and were to be disposed of in accordance with Circular No. 17/2019. The Revenue explicitly stated that the tax appeal was not pressed in view of the low tax effect, referencing the monetary limits prescribed in the aforementioned circular. The circular stipulates a monetary limit of Rs. 1,00,00,000 for appeals before the High Court. Consequently, the High 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. No specific findings were made on the merits of the original dispute.
The Tribunal noted that the captioned appeal was notified for the purpose of passing an appropriate order due to its low tax effect, in line with Circular No. 17/2019. The appeal was not pressed by the Revenue in view of this circular and the monetary limits prescribed therein. Specifically, for appeals before the High Court, the monetary limit is Rs. 1,00,00,000. Consequently, 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 made on the merits of the case.
The Tribunal decided that the appeal should be disposed of due to its low tax effect, in accordance with Circular No. 17/2019. The reasoning is based on the policy outlined in the circular, which sets monetary limits for appeals. For appeals before the High Court, the monetary limit is Rs. 1,00,00,000. Since the tax effect in this appeal is low, it falls within the scope of the circular's guidelines for not pursuing appeals. The operative direction is that the appeal is disposed of accordingly. The court reserves liberty for the Revenue to revive the tax appeal in case of any difficulty.
The High Court of Gujarat held that the 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 Court noted the monetary limits for appeals before various authorities as stipulated in the circular. 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. The ratio is that appeals with a low tax effect, falling below the prescribed monetary limits in CBDT circulars, may not be pressed and can be disposed of accordingly, with liberty to revive if necessary.
The High Court held that the appeal is not pressed in view of the low tax effect, as per Circular No. 17/2019. The Court noted the monetary limits for appeals before various authorities as per the circular. Consequently, the appeal was disposed of in accordance with this policy. The Court 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.
The High Court held that the 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, and the appeal in question falls below the threshold for High Court appeals. Consequently, the appeal was disposed of in line with this policy. 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 noted that the captioned appeal was not pressed in view of the low tax effect, as per 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. In light of this policy and the fact that the appeal was not pressed, the Court disposed of the 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, as the appeal was withdrawn/not pressed.
The High Court noted that the captioned appeal was not pressed in view of the low tax effect, as per 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. In light of this policy and the fact that the appeal was not pressed, the Court disposed of the 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, as the appeal was withdrawn/not pressed.
The High Court held that the Tax Appeal is not pressed by the appellant (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 monetary limit of Rs. 1,00,00,000. Since the appeal was not pressed, it was disposed of accordingly. The Court reserved the liberty for the Revenue to revive the tax appeal in case of any difficulty. No decision on the merits of the original dispute was made.
The High Court of Gujarat, in consideration of Circular No. 17/2019 and the fact that the appeal was not pressed by the Revenue due to low tax effect, disposed of the appeal. The court noted the monetary limits prescribed by the circular for appeals before the High Court, which is Rs. 1,00,00,000. The court reserved the liberty for the Revenue to revive the tax appeal in case of any difficulty. The specific tax effect or the merits of the original assessment were not adjudicated upon.
The High Court of Gujarat held that the Tax Appeal is not pressed by the Revenue due to the low tax effect, in accordance with Circular No. 17/2019. The circular establishes a monetary limit of Rs. 1,00,00,000 for appeals before the High Court. Since the appeal falls within the purview of this circular, it is disposed of accordingly. The Court reserved liberty for the Revenue 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. No decision on the merits of the appeal was made.
The High Court of Gujarat held that the Tax Appeal is not pressed by the appellant (Revenue) due to the low tax effect, in accordance with Circular No. 17/2019 dated August 8, 2019. The court acknowledged the policy outlined in the circular, which sets monetary limits for appeals at various levels, including before the High Court. Consequently, the appeal was disposed of in view of the aforesaid circular. The court also reserved the 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 order under challenge was decided.
The Tribunal decided that the appeal should be disposed of in view of the low tax effect, as per Circular No. 17/2019. The reasoning is that the Revenue has chosen not to press the appeal, aligning with the policy of not pursuing matters below certain monetary thresholds. The operative direction is to dispose of the appeal accordingly. The Revenue is 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 related to the Revenue's policy.
The High Court of Gujarat at Ahmedabad decided to dispose of the Tax Appeal. The Court noted that the appeal was not pressed by the appellant (Commissioner of Income Tax) due to its low tax effect, in line with Circular No. 17/2019. This circular establishes monetary limits for appeals before various judicial forums, including the High Court. Given that the appeal's tax effect was below the threshold stipulated by the circular for appeals before the High Court, 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 decision was made on the substantive merits of the tax dispute.
The Tribunal decided that the appeal was not pressed by the Revenue in view of the low tax effect, as per Circular No. 17/2019. The reasoning provided is that the monetary limit for appeals before the High Court is Rs. 1,00,00,000, and the current appeal falls under this category, making it eligible for disposal based on the circular. The High Court disposed of the appeal accordingly. The operative direction is that the appeal is disposed of. The court 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 based on the stated policy.
The High Court held that the appeal was not pressed by the Revenue in view of the low tax effect, as per Circular No. 17/2019. The Court noted the monetary limit for appeals before the High Court is Rs. 1,00,00,000. Consequently, the appeal was disposed of on this basis. The reasoning is directly tied to the policy laid down in the CBDT circular, which guides the department on pursuing appeals based on monetary limits. The ratio decidendi is that appeals with a low tax effect, below the prescribed monetary limits, are not to be pressed. The operative direction was to dispose of the appeal accordingly. Liberty was reserved for the Revenue to revive the tax appeal in case of any difficulty.
The Tribunal decided that the appeal was not pressed by the Revenue in view of the low tax effect, as per Circular No. 17/2019. The court noted the monetary limits specified in the circular for appeals before the High Court, which is Rs. 1,00,00,000. Since the appeal was not pressed, the court disposed of the appeal accordingly. The reasoning was based on the stated policy of the government to avoid litigation where the tax effect is below a certain threshold. The operative direction was to dispose of the appeal. The court also reserved the liberty for the Revenue to revive the tax appeal in case of any difficulty.
The Tribunal decided that the appeal was 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 Revenue was granted liberty to revive the tax appeal in case of any difficulty. No specific finding on the merits of the original assessment or the grounds of appeal was made, as the appeal was not pressed.
The Tribunal decided that the appeal was 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 Revenue was granted liberty to revive the tax appeal in case of any difficulty. No specific finding on the merits of the original assessment or the grounds of appeal was made, as the appeal was not pressed.
The Tribunal decided that the appeal was 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 Revenue was granted liberty to revive the tax appeal in case of any difficulty. No specific finding on the merits of the original assessment or the grounds of appeal was made, as the appeal was not pressed.
The High Court held that the appeal should be disposed of as not pressed, in view of the low tax effect and in accordance with CBDT Circular No. 17/2019. The circular provides monetary limits for appeals, with Rs. 1,00,00,000 being the limit for appeals before the High Court. Since the tax effect of the present appeal was below this limit, the Revenue chose not to pursue it. 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. No specific issue was left undecided, as the appeal was disposed of on procedural grounds based on the circular.
The High Court held that the appeal is not pressed in view of the low tax effect, as per Circular No. 17/2019. The Court noted the monetary limits for appeals before different judicial forums as stipulated in the circular. Consequently, the appeal was disposed of in accordance with this policy. 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, 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, aligning with Circular No. 17/2019. The court acknowledged the policy reflected in the circular, which sets monetary limits for appeals at various levels. Consequently, the appeal was disposed of in accordance with this policy. The court 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 order under challenge was decided.
The High Court of Gujarat held that the Tax Appeal is not pressed by the Revenue due to the low tax effect, in accordance with Circular No. 17/2019. The court noted the monetary limit for appeals before the High Court as Rs. 1,00,00,000 as per the circular. Consequently, the appeal was disposed of on this basis. 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 case, as the appeal was not pressed.
The High Court held that the appeal was not pressed by the Revenue in view of the low tax effect, as per Circular No. 17/2019. The Circular specifies monetary limits for filing appeals before various authorities, with appeals before the High Court having a monetary limit of Rs. 1,00,00,000. Since the tax effect was low, the appeal was disposed of accordingly. 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 of Gujarat held that the appeal is not pressed by the Revenue due to the low tax effect, in line with Circular No. 17/2019. The Court noted the monetary limits specified in the circular, which indicate that appeals with a tax effect below Rs. 1,00,00,000 before the High Court are generally not pursued. Consequently, the appeal was disposed of on this basis. The Court also reserved the liberty for the Revenue to revive the tax appeal in case of any difficulty. No decision was made on the merits of the case.
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 Court acknowledged the policy outlined in the circular, which sets monetary limits for appeals. Specifically, for appeals before the High Court, the monetary limit is Rs. 1,00,00,000. Given this, 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 amount in dispute was not recorded.
The Tribunal decided that the appeal should be disposed of in view of the low tax effect, as per Circular No. 17/2019 dated August 8, 2019. The Revenue stated that the appeal was not pressed on this ground. 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 specific finding on the merits of the original dispute is recorded as the appeal was not pressed.