Madras High Court Judgments — 2019

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, falling below the threshold limit stipulated in CBDT Circular No. 17/2019. The Court noted that the substantial question of law framed at the time of admission was 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 awarded.

The High Court did not decide the substantial questions of law on their merits. Instead, the appeals were dismissed on the ground of low tax effect, as per CBDT Circular No.17/2019, which raised the monetary threshold for filing appeals before the High Court to Rs.1 Crore. The Revenue submitted that the tax effect in these cases was below this limit. Consequently, the substantial questions of law 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, to be heard and decided on merits. 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, in light 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 appeal was dismissed on account of low tax effect. The substantial questions of law framed 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 awarded.

The High Court dismissed the appeal filed by the Revenue on the ground of low tax effect. The Revenue's counsel submitted that the appeal was not being pursued due to Circular No. 17/2019 issued by the CBDT, which increased the monetary limit for filing or pursuing appeals before the High Court to Rs. 1 Crore. The tax effect in this case was stated to be less than this threshold limit. Consequently, the appeal was dismissed without deciding the substantial questions of law, which were expressly 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 dismissed the appeal filed by the Revenue on account of low tax effect, as submitted by the learned counsel for the appellant. The Court noted that the appeal was filed against the ITAT's order concerning the applicability of Section 14A read with Rule 8D. The substantial question of law framed for 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 CBDT Circular No. 17/2019, to be heard and decided on merits. No costs were awarded. The specific finding of the ITAT on the substantial question of law was not discussed or decided by the High Court.

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 in this case was below the revised monetary threshold for pursuing appeals before the High Court. Consequently, the substantial questions of law framed at the time of admission 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 imposed. The operative direction was to dismiss the 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, 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 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 High Court dismissed the appeals filed by the Revenue on account 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 in these cases was below the increased monetary limit for appeals to the High Court. Consequently, the substantial questions of law framed for admission 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 fixed in the circular, allowing them to be heard and decided on merits. 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, in line with 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 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 seek restoration of the appeal 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 on the ground of low tax effect, citing Circular No. 17/2019 issued by the Central Board of Direct Taxes, which raised the monetary threshold for filing appeals before the High Court to Rs. 1 Crore. The Court noted that the tax effect in this particular case was below this limit. Consequently, the substantial questions of law framed 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 threshold limit, allowing it to be heard and decided on merits. No costs were awarded. The specific findings of the ITAT on the deemed dividend issue, the interpretation of the circular, and the commercial nexus 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's counsel that the appeal was not being pursued due to low tax effect, in light 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 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, for hearing and decision on merits. No costs were awarded.

The High Court of Madras dismissed the appeals filed by the Revenue. The dismissal was based on the submission made by the Revenue's counsel 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 or pursuing appeals before the High Court to Rs.1 Crore, and the tax effect in the respective cases was below this threshold. Consequently, the substantial questions of law framed in the appeals were 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 in the future. No costs were imposed, and the connected miscellaneous petition was closed.

The High Court dismissed the appeals filed by the Revenue. The dismissal was based on the submission made by the Revenue's counsel regarding the low tax effect in the respective cases, which fell 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. Consequently, the substantial questions of law framed by the Revenue were left open and not decided on merits. 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, allowing them to be heard and decided on merits. No costs were imposed. The connected miscellaneous petitions were also closed.

The High Court dismissed the appeal filed by the Revenue on account 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 less than the increased monetary limit of Rs. 1 Crore for pursuing appeals before the High Court. 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 decision was made on the merits of the substantial questions of law. The operative direction was to dismiss the appeal.

The High Court held that the substantial question of law framed for consideration has already been answered against the revenue by a Division Bench of the same court in T.C.A.No.405 of 2016 dated June 21, 2016. This earlier decision was followed and affirmed by the Hon'ble Supreme Court. Therefore, following the precedent set by the earlier judgment, the High Court dismissed the appeal filed by the revenue. The substantial question of law was answered against the revenue. No costs were awarded. The principle is that if a substantial question of law has been decided against the revenue by a coordinate bench and affirmed by the Supreme Court, a subsequent appeal on the same issue will be dismissed.

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 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 this case was below this threshold. 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 decision was made on the merits of the substantial questions of law.

The High Court of Judicature at Madras 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 a low tax effect, which was below the threshold limit prescribed by CBDT Circular No. 17/2019. The Court noted that the substantial question of law framed in the appeal was 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 awarded.

The High Court dismissed the appeal filed by the Revenue on account of low tax effect, as submitted by the Revenue's counsel. The Court noted that the tax effect was below the threshold limit stipulated in CBDT Circular No.17/2019. 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, allowing it to be heard and decided on merits. No costs were imposed. The judgment does not provide a decision 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, which raised the monetary limit for appeals to the High Court to Rs. 1 Crore. The Court noted that the tax effect in this case was below the threshold. 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, allowing for a decision on merits. No costs were awarded. The specific findings of the Tribunal on the disallowances under Section 14A and the provision for investments were not adjudicated by the High Court.

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 a low tax effect, falling below the threshold limit of Rs. 1 Crore stipulated in CBDT Circular No. 17/2019. The Court noted that the substantial questions of law framed in the appeal 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, for a decision on merits. 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 a low tax effect, in line with CBDT Circular No.17/2019, which increased the monetary limit for pursuing 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 in 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 enable the appeal to be heard and decided on merits. 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 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 this case was below that limit. The Court noted that the substantial question of law framed in the appeal was 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 in the future. No costs were awarded.

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, in line with 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 this particular case was below this limit. Consequently, the Revenue chose not to pursue the appeal on its merits. The substantial question of law framed by the court was 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 fixed in the circular, for 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 Revenue's submission was based on the increased monetary limit for appeals to the High Court. Consequently, the substantial questions of law framed at the time of admission 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 fixed in the circular, allowing it to be heard and decided on merits. No costs were imposed. The connected miscellaneous petition was also closed.

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 a low tax effect, in light of CBDT Circular No. 17/2019, which raised the monetary limit for filing appeals before the High Court to Rs. 1 Crore. The tax effect in this specific case was below the revised threshold. 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 fixed threshold, allowing it to be heard and decided on merits. No costs were awarded.

The High Court dismissed the appeal filed by the Revenue on account of low tax effect, citing Circular No. 17/2019 of the Central Board of Direct Taxes, which increased the monetary limit for pursuing 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 were left open. The Revenue was granted liberty to mention the case for restoration if the tax effect was found to be above the circular's limit. No costs were awarded. The ITAT's order was not decided on its merits.

The High Court dismissed the appeal filed by the Revenue. The dismissal was based on the low tax effect, as per Circular No. 17/2019 dated August 8, 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 specified threshold. 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, allowing for a decision on merits. No costs were awarded.

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, in line with 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 limit. Consequently, the substantial question of law framed at the time of admission 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 in the future. 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 the respective cases was below this limit. Consequently, the substantial questions of law framed were left open. The Revenue was granted liberty to mention the cases 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 on account of low tax effect, as submitted by the Revenue's counsel. The Court noted that the tax effect in the respective cases was less than the threshold limit stipulated in CBDT Circular No.17/2019. Consequently, the substantial questions of law framed at the time of admission were 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 costs were imposed. The ITAT's order on the merits of the Section 80IA deduction was 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 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 this case was below that limit. 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 appeal 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 on account of low tax effect, citing Circular No. 17/2019 of the CBDT, which increased the monetary limit for pursuing 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 mention the case for restoration if the tax effect was found to be above the threshold limit. No costs were awarded. The specific findings of the ITAT on the royalty expenditure and the application of Section 32(1) were not adjudicated on merits by the High Court.

The High Court dismissed the appeal filed by the Revenue on the ground 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 less than the increased monetary threshold for pursuing appeals before the High Court. Consequently, the substantial questions of law framed at the time of admission 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, for hearing and decision on merits. No costs were awarded. The operative direction was to dismiss the appeal.

The High Court dismissed the Tax Case 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 CBDT Circular No. 17/2019, which raised the monetary threshold for High Court appeals to Rs. 1 Crore. The Court noted that the tax effect in this case was below the revised threshold. Consequently, the appeal was dismissed on this procedural ground. The substantial questions of law that were framed for admission were expressly left open by the Court. 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 on the ground of low tax effect, as per CBDT Circular No. 17/2019. The Court noted that the tax effect in this case was below the revised threshold limit for filing appeals before the High Court. 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 imposed. The specific findings and reasoning of the ITAT on the substantial questions of law were not adjudicated upon by the High Court.

The High Court did not decide the substantial questions of law on merits. The Revenue 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 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 appeals were dismissed 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 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 appeal 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 less than the revised monetary limit for pursuing appeals before the High Court. 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 fixed in the circular, allowing it to be heard and decided on merits. No costs were awarded. The specific findings of the ITAT on the corpus fund and clubbing of receipts were not adjudicated upon by the High Court.

The High Court held that the substantial question of law framed in the appeal has been answered against the Revenue by the Hon'ble Supreme Court in the case of CIT vs. Rajasthan and Gujarati Charitable Foundation reported in [2018] 402 ITR 441 (SC). Following this precedent, the High Court dismissed the appeal filed by the Revenue. The substantial question of law was answered against the Revenue. No costs were awarded. The operative direction was the dismissal of the appeal.

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 that the Revenue's submission was that the tax effect in this case was below the revised threshold limit for pursuing appeals before the High Court. Consequently, the substantial questions of law framed at the time of admission 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 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 light of CBDT Circular No. 17/2019 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 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 High Court dismissed the appeal filed by the Revenue on the ground 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 less than the increased 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 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 ITAT's order was not adjudicated upon merits by the High Court.

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 mention the case for restoration if the tax effect was found to be above the threshold limit. No costs were awarded. The specific findings of the ITAT on the three substantial questions of law were not adjudicated upon by the High Court.

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, as per CBDT Circular No. 17/2019, which raised the monetary threshold for appeals to the High Court to Rs. 1 Crore. The tax effect in this case was below this limit. Consequently, the substantial questions of law framed for 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, allowing it to be heard and decided on merits. 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 a low tax effect, falling below the threshold limit of Rs. 1 Crore stipulated in CBDT Circular No. 17/2019. Consequently, the substantial questions of law framed for 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, allowing it to be heard and decided on merits. No costs were awarded. The specific findings on the merits of the penalty cancellation by the ITAT were not addressed.

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 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 the present case was below this limit. Consequently, the substantial question of law framed for the appeal 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 awarded.

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 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, to be heard and decided on merits. No costs were awarded.

The High Court dismissed the appeal filed by the Revenue on the ground of low tax effect, as per CBDT Circular No. 17/2019. The Court noted that the Revenue's counsel submitted that the appeal was not being pursued because the tax effect was less than the increased monetary limit of Rs. 1 Crore for appeals to the High Court. 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 is found to be above the threshold limit. No costs were awarded. The specific findings of the ITAT on the classification of gains from shares were not adjudicated upon by the High Court.

The High Court dismissed the appeal filed by the Revenue on account of low tax effect, as per CBDT Circular No. 17/2019. The Court noted that the monetary limit for filing appeals before the High Court had been increased to Rs. 1 Crore, and the tax effect in this case was below that 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 in the future. No costs were awarded. The specific findings on the substantial questions of law were not adjudicated on merits.

The High Court dismissed the appeals filed by the Revenue on account 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 in the respective cases was less than the increased threshold limit of Rs.1 Crore for filing or pursuing appeals before the High Court. Consequently, the substantial questions of law framed at the time of admission were left open. The Revenue was granted liberty to mention the case before the Court 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 judgment did not decide the merits of the substantial questions of law.

The High Court dismissed the appeals filed by the Revenue on account of low tax effect, as per CBDT Circular No. 17/2019. The Court noted that the tax effect in the respective cases was below the threshold limit of Rs. 1 Crore for pursuing appeals before the High Court. Consequently, the substantial questions of law framed for the appeals were left open. The Revenue was granted liberty to mention the case to the Court for restoration if the tax effect was found to be above the threshold limit, allowing for a decision on merits. No costs were awarded. The Tribunal's findings on the merits of the case, including the classification of shares as investments or business income and the review of its earlier order, were not adjudicated upon by the High Court.