Madras High Court Judgments — 2019

The High Court dismissed the appeal on the ground of low tax effect, as submitted by the Revenue. The Court noted that the tax effect was less than the threshold limit stipulated in CBDT Circular No. 17/2019. Consequently, the substantial questions of law framed were left open. The Revenue was granted liberty to mention the case for restoration if the tax effect was found to be above the threshold limit, to be heard and decided on merits. No costs were awarded. The specific findings of the ITAT on the disallowance under Section 14A and the reasoning behind the remittal were not adjudicated upon by the High Court.

The High Court dismissed the appeal filed by the Revenue on account of low tax effect, citing Circular No. 17/2019 of the CBDT, which increased the monetary limit for filing appeals before the High Court to Rs. 1 Crore. The Revenue's counsel submitted that the tax effect in this case was below this threshold. Consequently, the substantial questions of law raised by the Revenue were left open. The Court granted liberty to the Revenue to seek restoration of the appeal if the tax effect was found to be above the fixed threshold, allowing it to be heard and decided on merits. No decision was made on the merits of the substantial questions of law.

The High Court dismissed the appeal filed by the Revenue. The dismissal was based on the Revenue's submission that the appeal was not being pursued due to a low tax effect, falling below the threshold limit stipulated in CBDT Circular No. 17/2019. The Court noted that the substantial questions of law framed at the time of admission were left open. Liberty was granted to the Revenue to seek restoration of the appeal if the tax effect was found to be above the threshold limit. No costs were awarded. The specific findings of the ITAT on the allowability of depreciation on non-compete fees were not adjudicated upon by the High Court.

The High Court dismissed the appeal filed by the Revenue on the ground of low tax effect, citing CBDT Circular No.17/2019. The Court noted that the tax effect in this case was below the increased monetary limit for filing or pursuing appeals before the High Court, which is Rs.1 Crore. Consequently, the substantial questions of law framed were left open. The Revenue was granted liberty to seek restoration of the appeal if the tax effect was found to be above the threshold limit. No costs were awarded. The specific findings on the substantial questions of law were not adjudicated on merits.

The High Court noted that the assessee had filed another appeal, TCA.No.638 of 2019, which was allowed by the Court by a judgment dated 29.8.2019. In light of this prior judgment, the Court stated that no separate judgment was required in the present appeal. Therefore, the appeal was closed without delving into the merits of the substantial questions of law raised. The operative direction was to close the appeal. No specific finding was given on any of the issues raised, nor was any ratio decidendi established for these specific points in this judgment. The issue of rectification under Section 254(2) was also not decided on merits.

The High Court dismissed the appeals filed by the Revenue. The dismissal was based on the submission by the Revenue that they were not pursuing the appeals due to low tax effect, as per CBDT Circular No.17/2019, which raised the monetary limit for filing appeals before the High Court to Rs.1 Crore. The Court noted that the tax effect in these cases was below the specified threshold. Consequently, the substantial questions of law framed for the appeals were left open. The Revenue was granted liberty to mention the case for restoration if the tax effect was found to be above the threshold limit, allowing the appeals to be heard and decided on merits. No decision was made on the merits of the substantial questions of law.

The High Court dismissed the appeal filed by the Revenue. The dismissal was based on the submission made by the Revenue's counsel regarding the low tax effect, as per CBDT Circular No. 17/2019. The Court noted that the monetary limit for filing or pursuing an appeal before the High Court had been increased to Rs. 1 Crore, and the tax effect in this specific case was below that limit. Consequently, the substantial questions of law framed for the appeal were left open. The Revenue was granted liberty to mention the case for restoration if the tax effect was found to be above the threshold limit fixed in the circular, to be heard and decided on merits. No costs were awarded.

The High Court dismissed the appeals filed by the Revenue. The dismissal was based on the submission by the Revenue that the appeals were not being pursued due to low tax effect, as per CBDT Circular No. 17/2019, which raised the monetary threshold for appeals to the High Court to Rs. 1 Crore. The Court noted that the tax effect in these cases was below the specified limit. Consequently, the substantial questions of law framed were left open. The Revenue was granted liberty to seek restoration of the appeals if the tax effect was found to be above the threshold limit. No costs were imposed. The connected Civil Miscellaneous Petitions were also dismissed.

The High Court dismissed the appeals filed by the Revenue. The dismissal was based on the submission by the Revenue that the appeals were not being pursued due to a low tax effect, as per Circular No. 17/2019 of the Central Board of Direct Taxes, which raised the monetary limit for appeals to the High Court to Rs. 1 Crore. The Court noted that the tax effect in these cases was below the threshold limit. Consequently, the substantial questions of law framed were left open. Liberty was granted to the Revenue to seek restoration of the appeals if the tax effect was found to be above the threshold limit, to be heard and decided on merits. The connected civil miscellaneous petition was also dismissed. No costs were awarded.

The Revenue sought to withdraw the appeal on the grounds of low tax effect, citing CBDT Circular No.17/2019 dated 08.08.2019, which increased the monetary limit for filing appeals before the High Court to Rs.1 Crore. The Revenue submitted that the tax effect in this case was below this threshold. Consequently, the High Court dismissed the appeal on account of low tax effect. The substantial questions of law were left open. Liberty was granted to the Revenue to seek restoration of the appeal if the tax effect was found to be above the threshold limit. No costs were awarded.

The High Court dismissed the appeal filed by the Revenue on the ground of low tax effect, in light of CBDT Circular No.17/2019. The Court noted that the Revenue's counsel submitted that the appeal was not being pursued as the tax effect was below the revised monetary limit of Rs.1 Crore for appeals to the High Court. The substantial question of law framed at the time of admission was expressly left open. The Revenue was granted liberty to mention the case for restoration if the tax effect was found to be above the threshold limit. No costs were imposed.

The High Court dismissed the appeal filed by the Revenue. The dismissal was based on the Revenue's submission that the appeal was not being pursued due to low tax effect, in line with CBDT Circular No. 17/2019, which increased the monetary limit for filing appeals before the High Court to Rs. 1 Crore. The Court noted that the tax effect in this case was below the threshold limit. Consequently, the substantial questions of law were left open. The Revenue was granted liberty to mention the case for restoration if the tax effect was found to be above the threshold limit. No costs were awarded. The specific findings on the merits of the substantial questions of law were not adjudicated.

The High Court dismissed the appeal filed by the Revenue. The dismissal was based on the Revenue's submission that the appeal was not being pursued due to low tax effect, in terms of CBDT Circular No. 17/2019, which increased the monetary limit for filing appeals before the High Court to Rs. 1 Crore. The Court noted that the tax effect in this case was below the threshold limit. Consequently, the substantial questions of law framed at the time of admission were left open. The Revenue was granted liberty to mention the case for restoration if the tax effect was found to be above the threshold limit, to be heard and decided on merits. No costs were awarded.

The High Court dismissed the appeals filed by the Revenue. The Revenue's counsel submitted that the appeals were not being pursued due to low tax effect, as per CBDT Circular No.17/2019, which increased the monetary limit for filing appeals before the High Court to Rs.1 Crore. The tax effect in this case was below this threshold. Consequently, the appeals were dismissed on this ground. The Court explicitly stated that the substantial questions of law framed were left open. Liberty was granted to the Revenue to seek restoration of the appeals if the tax effect was found to be above the threshold limit. No costs were awarded. The connected miscellaneous petition was also closed.

The High Court dismissed the appeal filed by the Revenue. The dismissal was based on the submission made by the learned Senior Standing Counsel for the appellant (Revenue) that the appeal was not being pursued due to low tax effect, as per CBDT Circular No. 17/2019 dated August 8, 2019. This circular increased the monetary limit for filing or pursuing appeals before the High Court to Rs. 1 Crore. The Revenue stated that the tax effect in this case was below this threshold. Consequently, the substantial questions of law framed were left open. The Court granted liberty to the Revenue to mention the case for restoration if the tax effect was found to be above the threshold limit. No costs were awarded.

The High Court dismissed the appeals filed by the Revenue. The dismissal was based on the submission by the Revenue that the appeals were not being pursued due to a low tax effect, as per CBDT Circular No.17/2019. This circular increased the monetary limit for filing appeals before the High Court to Rs.1 Crore, and the tax effect in these cases was stated to be below this limit. Consequently, the appeals were dismissed on this administrative ground. The substantial question of law framed for consideration was expressly left open by the Court. The Revenue was granted liberty to mention the case for restoration if the tax effect was found to be above the threshold limit fixed in the circular, to be heard and decided on merits. No costs were awarded.

The High Court dismissed the appeal filed by the Revenue, answering the substantial question of law against the Revenue. The Court relied on its prior decision in the case of The Principal Commissioner of Income Tax, Salem vs. M/s. S-1308 Ammapet Primary Agricultural Cooperative Bank Ltd. The Court noted that the assessee society is registered under the TNCS Act, and its definition of 'members' includes 'associate members'. The Assessing Officer erred in distinguishing between A Class and B Class members. For Section 80P relief, the society only needs to be engaged in providing credit facilities to its members. The Court further clarified that Section 80P(4) excludes 'cooperative banks' but allows deductions for 'primary cooperative agricultural and rural development banks' and 'primary agricultural credit societies'. The assessee society, being a primary agricultural cooperative credit society, is eligible for the deduction. The Court also distinguished the facts from the Supreme Court's decision in Citizen Cooperative Society Limited, where the society engaged in activities contrary to its governing act and accepted deposits from non-members. The High Court found no good ground to entertain the Revenue's appeal.

The High Court dismissed the appeal filed by the Revenue. The dismissal was based on the Revenue's submission that the appeal was not being pursued due to a low tax effect, in line with CBDT Circular No. 17/2019, which increased the monetary limit for filing appeals before the High Court to Rs. 1 Crore. The Court noted that the tax effect in this case was below this threshold. Consequently, the substantial questions of law framed were left open. The Revenue was granted liberty to seek restoration of the appeal if the tax effect was found to be above the threshold limit, to be heard and decided on merits. No costs were awarded.

The High Court held that the substantial questions of law framed by the Revenue had already been decided against the Revenue by the Supreme Court in the case of CIT vs. Container Corporation of India Ltd. (2018) 404 ITR 0397 (SC). Furthermore, the High Court had previously considered identical questions in the case of M/s.A.S.Shipping Agencies Pvt. Ltd. vs. DCIT, Chennai. Following these precedents, the High Court dismissed the appeal filed by the Revenue and answered the substantial questions of law against the Revenue. No specific findings were recorded on each individual question by the High Court itself, as it relied on prior judicial pronouncements. The operative direction was the dismissal of the appeal.

The High Court dismissed the appeals filed by the Revenue. The dismissal was based on the submission by the Revenue's counsel that the appeals were not being pursued due to a low tax effect, which was below the threshold limit stipulated in CBDT Circular No.17/2019. The Court explicitly stated that the substantial questions of law framed were left open. Liberty was granted to the Revenue to seek restoration of the appeals if the tax effect was found to be above the threshold limit, for hearing and decision on merits. No costs were awarded. Consequently, the connected miscellaneous petition was also closed.

The High Court dismissed the appeals filed by the Revenue on account of low tax effect, as per CBDT Circular No. 17/2019, which increased the monetary limit for filing appeals before the High Court to Rs. 1 Crore. The Court noted that the tax effect in these appeals was below the threshold limit. Consequently, the substantial questions of law framed were left open. The Revenue was granted liberty to make a mention to the Court to restore the appeals if the tax effect was found to be above the fixed threshold limit, allowing them to be heard and decided on merits. No costs were imposed. The specific findings on the substantial questions of law were not adjudicated upon due to the dismissal on procedural grounds.

The High Court dismissed the appeals filed by the Revenue. The dismissal was based on the submission by the Revenue that the appeals were not being pursued due to low tax effect, as per CBDT Circular No.17/2019. The circular increased the monetary limit for filing appeals before the High Court to Rs.1 Crore, and the tax effect in these cases was below this limit. The Court explicitly stated that the substantial questions of law framed were left open. Liberty was granted to the Revenue to mention the case for restoration if the tax effect was found to be above the threshold limit, to be heard and decided on merits. No costs were imposed. The connected civil miscellaneous petition was also closed.

The High Court dismissed the appeals filed by the Revenue. The dismissal was based on the submission by the Revenue that the appeals were not being pursued due to a low tax effect, falling below the threshold limit stipulated in CBDT Circular No.17/2019. The Court noted that the monetary limit for filing or pursuing an appeal before the High Court had been increased to Rs.1 Crore by this circular. Consequently, the substantial questions of law framed earlier were left open. The Revenue was granted liberty to mention the case for restoration if the tax effect was found to be above the threshold limit. No costs were awarded.

The High Court held that the substantial questions of law raised in the appeals had already been answered in favour of the assessee in the assessee's own case in T.C.A.No.1248 of 2008, dated 08.10.2018. The Court followed its previous decision in that case, which in turn relied on the Hon'ble Supreme Court's decision in CIT vs. HCL Technologies Ltd. (2018) 404 ITR 0719. Therefore, the appeals filed by the Revenue were dismissed. The substantial questions of law were answered in favour of the assessee and against the Revenue. No costs were awarded.

The High Court dismissed the appeal filed by the Revenue. The dismissal was based on the Revenue's submission that the appeal was not being pursued due to low tax effect, in accordance with CBDT Circular No. 17/2019. This circular increased the monetary limit for filing appeals before the High Court to Rs. 1 Crore. The tax effect in the present case was stated to be below this threshold. Consequently, the substantial questions of law framed were left open and not decided on merits. The Revenue was granted liberty to seek restoration of the appeal if the tax effect was found to be above the threshold limit. No costs were awarded.

The High Court dismissed the appeal filed by the Revenue. The Revenue's counsel submitted that the appeal was not being pursued due to the low tax effect, citing CBDT Circular No. 17/2019, which increased the monetary limit for filing appeals before the High Court to Rs. 1 Crore. The tax effect in this case was stated to be below this threshold. Consequently, the appeal was dismissed on the grounds of low tax effect. The substantial questions of law framed were left open. The Revenue was granted liberty to mention the case for restoration if the tax effect was found to be above the threshold limit. No costs were awarded.

The High Court dismissed the Tax Case Appeal filed by the Revenue. The dismissal was based on the Revenue's submission that the appeal was not being pursued due to a low tax effect, as per CBDT Circular No. 17/2019. This circular increased the monetary limit for appeals to the High Court to Rs. 1 Crore, and the tax effect in this case was stated to be below this limit. Consequently, the substantial question of law framed by the court, concerning the exclusion of foreign currency travel and internet expenses from total turnover for Section 10B deduction, was left undecided. The court granted liberty to the Revenue to seek restoration of the appeal if the tax effect was found to be above the threshold limit. No costs were imposed.

The Revenue's counsel submitted that the appeal was not being pursued due to low tax effect, citing CBDT Circular No. 17/2019 which increased the monetary limit for filing appeals before the High Court to Rs. 1 Crore. The tax effect in this case was stated to be below this threshold. Consequently, the High Court dismissed the appeal on the ground of low tax effect. The substantial questions of law were left open. Liberty was granted to the Revenue to seek restoration of the appeal if the tax effect exceeded the threshold limit in the future. No costs were awarded.

The High Court dismissed the appeal filed by the Revenue. The dismissal was based on the submission by the Revenue's counsel that the appeal was not being pursued due to low tax effect, as per CBDT Circular No. 17/2019, which increased the monetary limit for filing appeals before the High Court to Rs. 1 Crore. The tax effect in this case was stated to be below this threshold. Consequently, the substantial questions of law were left open. The Court granted liberty to the Revenue to seek restoration of the appeal if the tax effect was found to be above the threshold limit. No costs were imposed. The specific findings of the Tribunal on the four issues raised were not adjudicated upon by the High Court.

The High Court dismissed the appeals filed by the Revenue on the ground of low tax effect. The Revenue's counsel submitted that the appeals were not being pursued due to the low tax effect, as per CBDT Circular No.17/2019, which increased the monetary limit for filing appeals before the High Court to Rs.1 Crore. The tax effect in these cases was stated to be below this threshold. Consequently, the substantial question of law framed at the time of admission was left open. The court granted liberty to the Revenue to seek restoration of the appeals if the tax effect was found to be above the threshold limit. No decision was made on the merits of the substantial question of law.

The High Court dismissed the appeals filed by the Revenue. The dismissal was based on the submission made by the learned Senior Standing Counsel for the appellant that the Revenue was not pursuing these appeals due to low tax effect, in terms of CBDT Circular No.17/2019, which increased the monetary limit for filing appeals before the High Court to Rs.1 Crore. The Court noted that the tax effect in these cases was below the threshold limit. Consequently, the appeals were dismissed on this ground. The substantial questions of law framed were left open. Liberty was granted to the Revenue to seek restoration of the appeals if the tax effect was found to be above the threshold limit, to be heard and decided on merits. No costs were imposed.

The High Court dismissed the appeal filed by the Revenue on the ground of low tax effect, citing CBDT Circular No. 17/2019. The Court noted that the Revenue's counsel submitted that the appeal was not being pursued due to the tax effect being below the enhanced monetary limit for appeals before the High Court, which is Rs. 1 Crore. Consequently, the substantial questions of law framed were left open. The Court granted liberty to the Revenue to seek restoration of the appeal if the tax effect was found to be above the threshold limit. No costs were awarded. The specific findings of the Tribunal on the forex derivative loss were not adjudicated upon by the High Court.

The High Court dismissed the appeal filed by the Revenue. The dismissal was based on the submission by the Revenue that the appeal was not being pursued due to a low tax effect, as per Circular No. 17/2019 issued by the Central Board of Direct Taxes, which increased the monetary limit for filing appeals before the High Court to Rs. 1 Crore. The tax effect in this case was stated to be below this threshold. Consequently, the substantial question of law framed in the appeal was left open. The Revenue was granted liberty to seek restoration of the appeal if the tax effect was found to be above the threshold limit.

The High Court dismissed the appeals filed by the Revenue. The dismissal was based on the Revenue's submission that the appeals were not being pursued due to a low tax effect, falling below the threshold limit stipulated in CBDT Circular No.17/2019. This circular increased the monetary limit for filing or pursuing appeals before the High Court to Rs. 1 Crore. The Court noted that the tax effect in these cases was less than this limit. Consequently, the appeals were dismissed on this procedural ground. The substantial question of law framed at the time of admission was explicitly left open by the Court. The Revenue was granted liberty to seek restoration of the appeals if the tax effect was found to be above the threshold limit, to be heard and decided on merits. No costs were awarded.

The High Court dismissed the appeals filed by the Revenue. The dismissal was based on the submission by the Revenue's counsel that the appeals were not being pursued due to low tax effect, as per Circular No. 17/2019 issued by the Central Board of Direct Taxes, which increased the monetary limit for filing appeals before the High Court to Rs. 1 Crore. The Court noted that the tax effect in this case was below the threshold limit. Consequently, the substantial questions of law framed were left open. The Revenue was granted liberty to mention the case for restoration if the tax effect was found to be above the threshold limit. No costs were awarded. The connected civil miscellaneous petition was also closed.

The High Court dismissed the appeal filed by the Revenue. The dismissal was based on the Revenue's submission that the appeal was not being pursued due to low tax effect, in line with CBDT Circular No.17/2019, which increased the monetary limit for filing appeals before the High Court to Rs.1 Crore. The Court noted that the tax effect in this case was below the threshold limit. Consequently, the substantial questions of law framed were left open. The Revenue was granted liberty to seek restoration of the appeal if the tax effect exceeded the threshold limit. No costs were imposed.

The High Court dismissed the appeal filed by the Revenue. The dismissal was based on the submission by the Revenue's counsel that the appeal was not being pursued due to low tax effect, as per CBDT Circular No. 17/2019. This circular increased the monetary limit for filing or pursuing appeals before the High Court to Rs. 1 Crore, and the tax effect in this case was below that threshold. Consequently, the substantial questions of law framed in the appeal were left open. The Court granted liberty to the Revenue to seek restoration of the appeal if the tax effect was found to be above the threshold limit. No decision was made on the merits of the substantial questions of law.

The High Court held that the substantial questions of law framed for consideration in these appeals had already been answered against the Revenue by the Supreme Court in the case of CIT vs. Container Corporation of India Ltd. (2018) 404 ITR 0397 (SC). The Court also noted that it had previously considered an identical question in the case of M/s.A.S.Shipping Agencies Pvt. Ltd. vs. DCIT, Chennai. Following these precedents, the High Court dismissed the appeals. The operative direction was the dismissal of the appeals, with no costs awarded. The specific findings of the ITAT on the eligibility of earnings and the exclusion from turnover were implicitly upheld by dismissing the Revenue's appeals.

The High Court dismissed the appeals filed by the Revenue on the ground of low tax effect, as per CBDT Circular No.17/2019. The learned Senior Standing Counsel for the appellant (Revenue) submitted that the tax effect in these cases was below the threshold limit stipulated in the circular. Consequently, the substantial questions of law framed were left open. The court granted liberty to the Revenue to mention the case for restoration if the tax effect was found to be above the threshold limit fixed in the circular. No costs were awarded. The judgment does not provide findings on the merits of the substantial questions of law.

The High Court dismissed the appeal filed by the Revenue on account of low tax effect, as per CBDT Circular No. 17/2019. The substantial question of law framed at the time of admission was left open. The Court granted liberty to the Revenue to seek restoration of the appeal if the tax effect was found to be above the threshold limit fixed in the circular, allowing it to be heard and decided on merits. No costs were imposed. The specific merits of the substantial question of law were not adjudicated upon.

The High Court dismissed the appeal filed by the Revenue. The dismissal was based on the Revenue's submission that the appeal was not being pursued due to low tax effect, as per CBDT Circular No. 17/2019, which increased the monetary limit for filing appeals before the High Court to Rs. 1 Crore. The Court noted that the tax effect in this case was below the threshold limit. Consequently, the substantial questions of law framed were left open. The Revenue was granted liberty to seek restoration of the appeal if the tax effect was found to be above the threshold limit. No costs were awarded.

The High Court did not decide the substantial questions of law on merits. The Revenue submitted that the appeal was not being pursued due to a low tax effect, citing Circular No.17/2019 issued by the CBDT, which increased the monetary limit for filing appeals before the High Court to Rs. 1 Crore. The Revenue stated that the tax effect in this case was below this threshold. Consequently, the High Court dismissed the appeal on the ground of low tax effect. The substantial questions of law were expressly left open. Liberty was granted to the Revenue to seek restoration of the appeal if the tax effect was found to be above the threshold limit.

The High Court dismissed the appeal filed by the Revenue. The dismissal was based on the submission made by the Revenue's counsel regarding the low tax effect, referencing CBDT Circular No. 17/2019. This circular raised the monetary threshold for filing appeals before the High Court to Rs. 1 Crore, and the tax effect in the present case was stated to be below this limit. Consequently, the substantial question of law framed by the Revenue was left open. The Court granted liberty to the Revenue to seek restoration of the appeal if the tax effect was found to be above the threshold limit fixed in the circular, allowing it to be heard and decided on merits. No costs were imposed.

The High Court dismissed the appeals filed by the Revenue on the grounds of low tax effect, as per CBDT Circular No.17/2019. The Court noted the submission by the Revenue's counsel that the tax effect was below the threshold limit of Rs.1 Crore for pursuing appeals before the High Court. Consequently, the substantial questions of law framed were left open. The Revenue was granted liberty to seek restoration of the appeals if the tax effect was found to be above the fixed threshold limit. No costs were awarded. The ITAT's order was not adjudicated on its merits.

The High Court dismissed the appeal filed by the Revenue on the grounds of low tax effect, citing CBDT Circular No. 17/2019. The Court noted that the tax effect in this case was below the revised monetary limit for filing or pursuing appeals before the High Court. Consequently, the substantial questions of law framed in the appeal were left open. The Court granted liberty to the Revenue to mention the case for restoration if the tax effect was found to be above the threshold limit, allowing for a decision on merits. No costs were imposed. The specific findings of the ITAT on the three issues raised were not adjudicated upon by the High Court.

The High Court dismissed the appeal filed by the Revenue on the ground of low tax effect, in line with CBDT Circular No. 17/2019. The Court noted the submission by the Revenue's counsel that the tax effect was below the revised monetary limit for appeals to the High Court. Consequently, the substantial questions of law framed for determination were left open. The Revenue was granted liberty to mention the case for restoration if the tax effect is found to be above the threshold limit fixed in the circular, allowing for a hearing and decision on merits. No costs were awarded.

The High Court dismissed the appeal filed by the Revenue on the grounds of low tax effect, as per CBDT Circular No. 17/2019. The Court noted that the tax effect was below the revised threshold limit for pursuing appeals before the High Court. Consequently, the substantial question of law framed in the appeal was left open. The Revenue was granted liberty to mention the case for restoration if the tax effect was found to be above the threshold limit. No costs were awarded. The specific finding of the Tribunal on the eligibility of the Container Freight Station for deduction under Section 80IA(4) was not adjudicated upon by the High Court.

The High Court dismissed the appeal filed by the Revenue on the ground of low tax effect, citing Circular No. 17/2019 dated 08.08.2019 issued by the CBDT, which increased the monetary limit for filing appeals before the High Court to Rs. 1 Crore. The Court noted that the tax effect in this case was below the threshold limit. Consequently, the substantial questions of law framed were left open. The Revenue was granted liberty to mention the case for restoration if the tax effect was found to be above the threshold limit. No costs were imposed. The specific findings or reasoning on the merits of the substantial questions of law were not addressed due to the dismissal on procedural grounds.

The High Court dismissed the appeal filed by the Revenue. The dismissal was based on the Revenue's submission that the appeal was not being pursued due to a low tax effect, falling below the threshold limit stipulated in CBDT Circular No. 17/2019. Consequently, the substantial questions of law framed for the appeal were left undecided. The Court granted liberty to the Revenue to seek restoration of the appeal if the tax effect was found to be above the threshold limit, allowing it to be heard and decided on merits. No costs were awarded.

The High Court did not decide the substantial questions of law on merits. The Revenue submitted that it was not pursuing the appeal due to the low tax effect, citing CBDT Circular No. 17/2019, which increased the monetary limit for filing appeals before the High Court to Rs. 1 Crore. As the tax effect in this case was below the threshold, the appeal was dismissed. The Court explicitly stated that the substantial questions of law were left open. Liberty was granted to the Revenue to seek restoration of the appeal if the tax effect was found to be above the threshold limit, to be heard and decided on merits. No costs were imposed.