Madras High Court Judgments — 2019

The High Court dismissed the appeal on the grounds 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 revised 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 the appeal to be heard and decided on merits. No costs were awarded. The specific findings of the ITAT on the two substantial questions of law 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 of the Revenue's counsel regarding the tax effect being 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 in the future. No costs were awarded. The ITAT's order was not decided on merits.

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 raised the monetary limit for appeals to 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 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 held that the appeal did not raise any substantial question of law. The Court found that the issue agitated before it was entirely factual. The claim for deduction under Section 80RRA was considered by the Assessing Officer, the Commissioner of Income Tax (Appeals), and the Tribunal, all of whom concurrently ruled against the assessee. Crucially, the Court noted that the assessee had admittedly not produced any material to establish his entitlement to the benefit of deduction under Section 80RRA. Therefore, the Court concluded that there was no question of law, let alone a substantial question of law, arising for consideration. Consequently, the appeal was dismissed. No specific finding was given on each of the four questions of law as the Court deemed the matter purely factual.

The High Court held that the entire matter revolved around factual aspects that were not established by the assessee to the satisfaction of the Assessing Officer for entitlement to relief under Section 68 of the Act. The Court found the Tribunal's finding in paragraph 13.1 to be correct, noting that Dr. M.S. Kamesh Kumar was not the vendor but a facilitator, and the assessee's theory of returning the advance was not substantiated. The Court found no good grounds to interfere with the order of the Tribunal and held that no substantial question of law arose for consideration. Consequently, the appeal was dismissed, and the substantial questions of law were decided against the assessee. No issue was expressly left undecided.

The High Court held that the issue agitated before it was entirely factual and that no substantial question of law arose for consideration. The Court noted that the assessee's claim for deduction under Section 80RRA was considered by the Assessing Officer, CIT(A), and the ITAT, all of whom concurrently ruled against the assessee. Crucially, the Court observed that the assessee had admitted to not producing any material to establish his entitlement to the deduction under Section 80RRA. Consequently, the High Court found no basis to interfere with the ITAT's order. The appeal was dismissed on the grounds that it did not involve a substantial question of law. No specific findings were made on the merits of each of the five questions of law as the appeal was disposed of on a preliminary ground.

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 monetary limit for filing or pursuing an appeal before the High Court had been increased to Rs. 1 Crore by CBDT Circular No. 17/2019, and the tax effect in this case was less than the threshold. 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. No costs were awarded. The specific findings of the ITAT on the classification of gains 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 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 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 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 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 ITAT's order, which directed recomputation of income for Section 10A and 10B deductions, was not adjudicated on merits 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, 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 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 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, falling below 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, allowing them to be heard and decided on merits. No costs were imposed. The specific findings on the merits of the penalty proceedings under Section 271(1)(c) were not adjudicated.

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, which increased the monetary limit for appeals to the High Court to Rs. 1 Crore. The tax effect in this particular case was below the stipulated threshold. 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 awarded.

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, referencing CBDT Circular No. 17/2019. The Court noted that the tax effect in the respective cases was less than the threshold limit stipulated in the circular. Consequently, the appeals were dismissed on this ground. The substantial question of law framed at the time of admission was left open. The Court also 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 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 the low tax effect, which was 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 of 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. 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 Circular No.17/2019 issued by the CBDT. 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 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 fixed threshold limit. No costs were awarded.

The High Court dismissed the appeal on the ground of low tax effect, as per CBDT Circular No.17/2019. The Court noted the submission by the Revenue that the tax effect 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 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 disallowance of commission and the applicability of Section 195 and Section 9 were not adjudicated upon by the High Court.

The High Court dismissed the appeal filed by the Revenue on account of low tax effect, in light of 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 that the tax effect in this particular case was less than 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 appeal for hearing and decision on merits if the tax effect was found to be above the threshold limit fixed in the circular. 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 that the appeal was not being pursued due to a low tax effect, in accordance with CBDT Circular No. 17/2019. The 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. The Court explicitly stated that the substantial questions of law framed were left open. Liberty was granted to the Revenue to make a mention to the Court to restore the appeal for hearing and decision on merits if the tax effect was found to be above the threshold limit fixed in the circular. 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 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 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 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, which raised 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 prescribed 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 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, which raised the monetary limit for filing appeals before the High Court to Rs.1 Crore. The tax effect in this particular case was stated to be below this threshold. 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 fixed 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 submission by the Revenue's counsel that the appeal was 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. 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. The dismissal was based on the Revenue's submission that the appeal was 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, 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 that the appeal was not being pursued due to 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 by the said circular and that the tax effect in this case was less than 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 make a mention to the Court to restore 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 account of low tax effect, in light of the submissions made by the Revenue's counsel and CBDT Circular No. 17/2019. The substantial question of law framed by the Revenue was 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 fixed in the circular, to be heard and decided on merits. No costs were awarded. The specific finding of the ITAT regarding the estimation of income at 5% of total turnover 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'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 appeals to 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 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 on the substantial questions of law were not adjudicated on merits.

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 threshold for appeals to the High Court to Rs. 1 Crore. The Court noted that the tax effect in this case was below the specified 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. No costs were awarded. The specific findings on the merits of the substantial questions of law were not decided.

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. 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, and the tax effect in the present case was below this limit. Consequently, the appeal was dismissed on this ground. 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 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. 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. The Court noted that the monetary limit for filing or pursuing appeals before the High Court had been increased to Rs. 1 Crore and that the tax effect in this case was below this 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 fixed in the circular, 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 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 less than 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. 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, 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 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 appeals filed by the Revenue. The dismissal was based on the Revenue's submission that they were not pursuing the appeals due to low tax effect, citing 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 these cases 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. No costs were imposed.

The High Court dismissed both Tax Case 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 the low tax effect, which was 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 explicitly stated that the substantial questions of law framed in both appeals 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 imposed.

The High Court dismissed the appeal filed by the Revenue on the grounds 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 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 decision was made on the merits of the substantial questions of law. 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, citing 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 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, allowing the appeal 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. 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, and the tax effect in the respective cases was less than this threshold. Consequently, the appeals were dismissed on the ground of low tax effect. The substantial questions of law framed at the time of admission were expressly 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.

The High Court dismissed the appeal filed by the Revenue on the grounds of low tax effect, as submitted by the Revenue's counsel. The court noted that the tax effect in this case was below 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 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 penalty deletion by the ITAT 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, as per CBDT Circular No. 17/2019, which increased the monetary threshold for filing appeals before the High Court to Rs. 1 Crore. The Court noted that the tax effect in this case was below this 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 the appeal to be heard and decided on merits. No costs were awarded. The specific findings on the substantial questions of law were not made as the appeal was disposed of on a procedural ground.

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 learned Senior Standing Counsel for the Revenue submitted that the appeal was not being pursued because the tax effect was less than the increased monetary limit of Rs. 1 Crore for filing appeals before the High Court. Consequently, the substantial question of law framed by the court 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 appeals filed by the Revenue. The dismissal was based on the Revenue's submission that it was not pursuing the appeals due to a 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 these cases was below the threshold. Consequently, the substantial questions of law framed for 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, allowing for a decision on merits. No costs were imposed.

The High Court noted the submission by the Revenue's counsel regarding the low tax effect in the present appeal, citing CBDT Circular No. 17/2019. This circular increased the monetary limit for filing appeals before the High Court to Rs. 1 Crore. The Revenue stated that the tax effect in this particular case falls below this threshold. Consequently, the High Court dismissed the appeal on the grounds of low tax effect. The substantial questions of law framed at the time of admission were expressly 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 fixed threshold limit, allowing for a decision on merits. No costs were awarded.

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 monetary limit for filing or pursuing an appeal before the High Court has been increased to Rs. 1 Crore, and the tax effect in this case was less than the threshold. The substantial questions of law framed for admission were left open. The Revenue was granted liberty to mention the case before the Court to restore the appeal for hearing on merits if the tax effect is found to be above the threshold limit fixed in the circular. No costs were awarded. The specific findings on the substantial questions of law were not decided on merits.

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 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 these respective cases was less than this threshold. 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. No costs were awarded. The specific findings of the ITAT on the issues of goodwill and non-compete fee 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 submitted by the Revenue's counsel. The Court noted that the monetary limit for filing or pursuing an appeal before the High Court has been increased to Rs. 1 Crore by CBDT Circular No. 17/2019, and the tax effect in this case was less than this threshold. Consequently, the appeal was dismissed without deciding the substantial questions of law framed. 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 limit, allowing it to be heard and decided 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 threshold limit of Rs. 1 Crore for filing or pursuing appeals before the High Court. Consequently, the appeals were dismissed without deciding the substantial questions of law. 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, 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, citing 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 below the revised monetary limit of Rs.1 Crore for appeals before the High Court. Consequently, the substantial question of law framed at the time of admission was left undecided. 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, in light of the submissions made by the Revenue regarding the low tax effect, dismissed the appeals. The Court noted that the monetary limit for filing appeals before the High Court had been increased to Rs.1 Crore by CBDT Circular No.17/2019, and the tax effect in these cases was below this limit. Consequently, the appeals were dismissed on this ground. The substantial questions of law framed were expressly 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, allowing them to be heard and decided on merits. No costs were awarded. The specific findings of the ITAT on the three issues were not adjudicated by the High Court.

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, falling below the threshold limit of Rs.1 Crore for filing or pursuing appeals before the High Court, as stipulated in CBDT Circular No.17/2019 dated 08.08.2019. Consequently, the substantial questions of law framed 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, allowing them to be heard and decided on merits. No costs were awarded. The specific findings of the ITAT on the disallowance under Section 36(1)(iii) were not adjudicated 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 Revenue's counsel submitted that the appeal was not being pursued because the tax effect was below the increased monetary limit for High Court appeals. 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. 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, in line with CBDT Circular No. 17/2019. This circular 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. 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.