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331 orders · Page 3 of 7
The High Court noted that the Revenue, through its learned Senior Standing Counsel, brought to its attention CBDT Circular No. 17/2019. This circular stipulates that appeals shall not be filed or pursued by the Department before the High Court if the tax effect does not exceed Rs. 1,00,00,000/-. The Revenue further submitted that the tax effect in the present appeals was less than this threshold limit. In light of this submission by the Revenue, the High Court dismissed the present appeals as withdrawn. The court stated that the substantial question of law is kept open for determination in appropriate cases. No costs were awarded, and the connected miscellaneous petition was closed.
The High Court noted that the Revenue's counsel brought to its attention CBDT Circular No. 17/2019, which mandates that appeals shall not be filed or pursued before the High Court if the tax effect does not exceed Rs. 1,00,00,000/-. The Revenue submitted that the tax effect in the present appeal was less than this threshold limit. In light of this submission, the High Court dismissed the appeal as withdrawn. The court explicitly stated that the substantial questions of law were kept open for determination in an appropriate case. No costs were awarded.
The High Court noted the submission by the Revenue's counsel regarding CBDT Circular No. 17/2019, which mandates that appeals shall not be filed or pursued by the Department before the High Court if the tax effect does not exceed Rs. 1,00,00,000/-. The Revenue stated that the tax effect in this particular appeal was below this monetary limit. In light of this submission, the Court dismissed the appeal as withdrawn. The substantial question of law was kept open for determination in an appropriate case. No costs were awarded.
The High Court did not decide the substantial questions of law on merits. The learned counsel for the appellant/Revenue brought to the court's notice Circular No. 17/2019 issued by the CBDT, which stipulates that appeals shall not be filed or pursued by the Department before the High Court if the tax effect does not exceed Rs. 1,00,00,000/-. It was submitted that the tax effect in this appeal was less than the threshold limit. Consequently, the High Court dismissed the appeal as withdrawn, keeping the substantial questions of law open for determination in an appropriate case. No costs were awarded. The connected miscellaneous petition was also closed.
The High Court noted that during the pendency of the Tax Case Appeal, the assessee had availed the benefit of the Direct Tax Vivad Se Vishwas Act, 2020. The assessee had filed necessary declarations, which were accepted, and an order for full and final settlement of tax arrears was issued by the Income Tax Department on 07.12.2021. The learned Standing Counsel for the Revenue fairly conceded this subsequent development. Consequently, the High Court was of the opinion that nothing survived for adjudication in the appeal. The appeal was disposed of based on the submissions made by both parties. No specific finding was given on the substantial questions of law raised, as the appeal was settled under the Vivad Se Vishwas Act.
The High Court of Judicature at Madras did not decide the substantial questions of law on merits. The learned Standing Counsels for the appellant/Revenue brought to the court's notice Circular No. 17/2019 dated August 8, 2019, issued by the Central Board of Direct Taxes (CBDT). This circular stipulates that appeals shall not be filed or pursued before the High Court if the tax effect does not exceed Rs. 1,00,00,000/-. The Revenue submitted that the tax effect in the present appeal was below this threshold limit. Consequently, the High Court dismissed the appeal as withdrawn, keeping the substantial questions of law open for determination in an appropriate case. No costs were awarded.
The High Court dismissed the appeal as withdrawn. The dismissal was based on the submission by the Revenue that the tax effect in the appeal was less than the threshold limit of Rs. 1,00,00,000/- stipulated in CBDT Circular No. 17/2019. The Court explicitly stated that the substantial questions of law were kept open for determination in an appropriate case. Therefore, there was no decision on the merits of the substantial questions of law regarding the allowability of provision for leave salary under Section 43B(f). No costs were awarded.
The High Court dismissed the appeals as withdrawn. The Revenue brought to the court's notice Circular No. 17/2019 issued by the Central Board of Direct Taxes (CBDT), which stipulates that appeals shall not be filed or pursued by the Department before the High Court if the tax effect does not exceed Rs. 1,00,00,000/-. The Revenue submitted that the tax effect in these appeals was less than the threshold limit. Consequently, the High Court, in light of the CBDT circular and the submission regarding the tax effect being below the monetary limit, dismissed the present appeals as withdrawn. The substantial questions of law were kept open for determination in appropriate cases. No costs were awarded.
The High Court did not decide the substantial questions of law on merits. Instead, the learned counsel for the appellant/Revenue brought to the court's notice Circular No. 17/2019 dated 08.08.2019 issued by the Central Board of Direct Taxes (CBDT). This circular stipulates that appeals shall not be filed or pursued by the Department before the High Court if the tax effect does not exceed Rs. 1,00,00,000/-. The Revenue submitted that the tax effect in the present appeal was less than this threshold limit. Consequently, the High Court dismissed the appeal as withdrawn, keeping the substantial questions of law open for determination in an appropriate case. No costs were awarded.
The High Court noted that during the pendency of the appeal, the assessee had availed the benefit of the Direct Tax Vivad Se Vishwas Act, 2020, and had filed declarations which were accepted, leading to an order for full and final settlement of tax arrears on 22.01.2021. The learned counsel for the appellant/Revenue submitted this fact, which was fairly conceded by the learned counsel for the respondent/assessee. In view of this subsequent development, the High Court was of the opinion that nothing survived for adjudication in the appeal. The appeal was disposed of based on the submissions made by the counsel on either side, without deciding the substantial questions of law on merits. No costs were awarded.
The High Court, in light of the submission made by the learned counsel for the appellant/Revenue regarding CBDT Circular No. 17/2019, which mandates that appeals shall not be filed or pursued if the tax effect does not exceed Rs. 1,00,00,000/-, noted that the tax effect in this appeal was below the stipulated threshold. Consequently, the Court dismissed the appeal as withdrawn. The substantial question of law was kept open for determination in an appropriate case. No costs were awarded. The finding on the substantial question of law itself was not adjudicated upon by the High Court.
The High Court noted the submission by the Revenue regarding CBDT Circular No. 17/2019, which sets a monetary limit of Rs. 1,00,00,000/- for filing or pursuing appeals before the High Court. The Revenue stated that the tax effect in the present appeal was below this stipulated threshold. Consequently, the High Court, in light of the Revenue's submission and the circular, dismissed the appeal as withdrawn. The court explicitly stated that the substantial question of law was kept open for determination in an appropriate case. No costs were awarded. The judgment did not decide the substantial question of law on its merits.
The High Court, in light of the submission by the Revenue regarding CBDT Circular No. 17/2019, dismissed the appeals as withdrawn. The court noted that the tax effect in these appeals was less than the monetary limit imposed by the circular. The substantial questions of law were kept open for determination in appropriate cases. No costs were awarded. The court did not decide the merits of the substantial questions of law raised in the appeals.
The High Court, in light of the submission by the Revenue regarding CBDT Circular No.17/2019 and the tax effect being below the stipulated threshold of Rs. 1,00,00,000/-, dismissed the appeal as withdrawn. The court explicitly stated that the substantial questions of law were kept open for determination in an appropriate case. No costs were awarded. The judgment did not delve into the merits of the substantial questions of law as the appeal was disposed of on procedural grounds related to the tax effect and the circular.
The High Court dismissed the appeal as withdrawn. The Revenue brought to the court's notice CBDT Circular No. 17/2019, which stipulates that appeals shall not be filed or pursued if the tax effect does not exceed Rs. 1,00,00,000/-. The Revenue submitted that the tax effect in this appeal was below this threshold limit. Consequently, the appeal was dismissed as withdrawn, with the substantial questions of law left open for determination in an appropriate case. No costs were awarded. The specific findings of the ITAT on the capitation fee addition and the set-off of income application were not adjudicated by the High Court due to the withdrawal of the appeal.
The High Court did not decide the substantial questions of law on merits. Instead, the appeal was dismissed as withdrawn by the Revenue. This decision was based on the submission by the Revenue's counsel that the tax effect in the appeal was less than the threshold limit of Rs. 1,00,00,000/- stipulated in CBDT Circular No. 17/2019. The Court noted that the substantial questions of law were kept open for determination in an appropriate case. Therefore, there is no finding on the issues of deemed dividend under Section 2(22)(e), disallowance of commission under Section 40A(2)(b), or the computation of interest under Sections 234A and 234B. The operative direction was to dismiss the appeal as withdrawn.
The High Court noted the submission by the Revenue regarding CBDT Circular No. 17/2019, which mandates that appeals shall not be filed or pursued if the tax effect does not exceed Rs. 1,00,00,000/-. The Revenue stated that the tax effect in the present appeal was below this monetary limit. Consequently, the High Court dismissed the appeal as withdrawn, while explicitly stating that the substantial questions of law were kept open for determination in an appropriate case. No costs were awarded. The judgment did not provide findings on the merits of the substantial questions of law.
The High Court did not decide the substantial questions of law on merits. The learned counsel for the appellant/Revenue brought to the court's notice Circular No.17/2019 dated 08.08.2019 issued by the Central Board of Direct Taxes (CBDT). This circular stipulates that appeals shall not be filed or pursued by the Department before the High Court if the tax effect does not exceed Rs.1,00,00,000/- (Rupees One Crore). The Revenue submitted that the tax effect in the present appeal was less than this threshold limit. Consequently, the High Court dismissed the appeal as withdrawn, stating that the substantial questions of law were kept open for determination in an appropriate case. No costs were awarded.
The High Court did not decide the substantial questions of law on merits. The learned counsel for the appellant/Revenue brought to the court's notice CBDT Circular No. 17/2019 dated 08.08.2019, which stipulates that appeals shall not be filed or pursued by the Department before the High Court if the tax effect does not exceed Rs. 1,00,00,000/-. It was submitted that the tax effect in this appeal was below this threshold limit. Consequently, the High Court dismissed the appeal as withdrawn, keeping the substantial questions of law open for determination in an appropriate case. No costs were awarded.
The High Court noted the submission by the Revenue regarding CBDT Circular No. 17/2019, which sets a monetary threshold of Rs. 1,00,00,000/- for filing or pursuing appeals before the High Court. The Revenue stated that the tax effect in the present appeal was below this limit. In light of this submission, the High Court dismissed the appeal as withdrawn. The substantial question of law was kept open for determination in an appropriate case. No costs were awarded.
The High Court, in light of the submission by the Revenue regarding CBDT Circular No. 17/2019, which mandates that appeals shall not be filed or pursued if the tax effect does not exceed Rs. 1,00,00,000/-, noted that the tax effect in the present appeal was below this monetary limit. Consequently, the Court dismissed the appeal as withdrawn. The substantial questions of law were kept open for determination in an appropriate case. No costs were awarded.
The High Court did not delve into the merits of the substantial questions of law. Instead, relying on the submission made by the Revenue's counsel regarding CBDT Circular No. 17/2019, which mandates that appeals with a tax effect not exceeding Rs. 1,00,00,000/- should not be filed or pursued, the Court found that the tax effect in the present appeals was below this monetary limit. Consequently, the appeals were dismissed as withdrawn. The Court explicitly stated that the substantial questions of law remain open for determination in appropriate cases. No costs were awarded.
The High Court dismissed the appeal as withdrawn. The dismissal was based on the submission made by the learned counsel for the appellant/Revenue regarding CBDT Circular No. 17/2019. This circular mandates that appeals shall not be filed or pursued by the Department before the High Court in cases where the tax effect does not exceed Rs. 1,00,00,000/-. Since the tax effect in the present appeal was stated to be less than this monetary limit, the appeal was disposed of as withdrawn. The Court explicitly stated that the substantial question of law was kept open for determination in an appropriate case. No costs were awarded.
The High Court noted that the learned counsel for the appellant/Revenue brought to its notice CBDT Circular No. 17/2019 dated 08.08.2019. This circular stipulates that appeals shall not be filed or pursued by the Department before the High Court if the tax effect does not exceed Rs. 1,00,00,000/- (Rupees One Crore). The Revenue submitted that the tax effect in the present appeal was less than this threshold limit. Consequently, the High Court dismissed the appeal as withdrawn, stating that the substantial questions of law were kept open for determination in an appropriate case. No costs were awarded.
The High Court noted the submission by the Revenue regarding CBDT Circular No.17/2019, which mandates that appeals shall not be filed or pursued by the Department before the High Court if the tax effect does not exceed Rs.1,00,00,000/-. The Revenue confirmed that the tax effect in the present appeal was below this monetary limit. Consequently, the High Court dismissed the appeal as withdrawn, while explicitly stating that the substantial questions of law were kept open for determination in an appropriate case. No costs were awarded. The specific findings of the ITAT on the merits of the additions and deletions were not adjudicated by the High Court due to the withdrawal of the appeal.
The High Court did not decide the substantial questions of law on their merits. Instead, the Court took note of the submission by the Revenue's counsel regarding CBDT Circular No. 17/2019, which mandates that appeals shall not be filed or pursued if the tax effect does not exceed Rs. 1,00,00,000/-. As the tax effect in the present appeal was stated to be less than this threshold limit, the High Court dismissed the appeal as withdrawn. The Court explicitly stated that the substantial questions of law were kept open for determination in an appropriate case. No costs were awarded. The judgment does not contain any finding on the allowability of nomination fees or the applicability of the principle of overriding title.
The High Court did not decide the substantial questions of law on their merits. Instead, the Revenue's counsel brought to the court's notice CBDT Circular No.17/2019, which stipulates that appeals should not be filed or pursued if the tax effect is less than Rs.1,00,00,000/-. The counsel confirmed that the tax effect in the present appeal was below this monetary limit. Consequently, the High Court dismissed the appeal as withdrawn, stating that the substantial questions of law were kept open for determination in an appropriate case. No costs were awarded.
The High Court did not decide the substantial questions of law on merits. The learned counsel for the Revenue brought to the court's notice CBDT Circular No.17/2019 dated August 8, 2019. This circular stipulates that appeals shall not be filed or pursued by the Department before the High Court if the tax effect does not exceed Rs. 1,00,00,000/- (Rupees One Crore). The Revenue submitted that the tax effect in the present appeal was less than this threshold limit. Consequently, the High Court dismissed the appeal as withdrawn, in light of the submission regarding the tax effect being below the monetary limit. The court explicitly stated that the substantial questions of law were kept open for determination in an appropriate case. No costs were awarded.
The High Court noted the submission by the Revenue's counsel regarding CBDT Circular No. 17/2019, which sets a monetary limit of Rs. 1,00,00,000/- for filing or pursuing appeals before the High Court. The Revenue confirmed that the tax effect in the present appeal was below this threshold. Consequently, the High Court dismissed the appeal as withdrawn, without deciding on the substantial question of law. The court explicitly stated that the substantial question of law was kept open for determination in an appropriate case. No costs were awarded.
The High Court did not decide the substantial questions of law on merits. Instead, the learned counsel for the appellant/Revenue brought to the court's notice CBDT Circular No.17/2019 dated 08.08.2019. This circular stipulates that appeals shall not be filed or pursued by the Department before the High Court if the tax effect does not exceed Rs.1,00,00,000/- (Rupees One Crore). The Revenue submitted that the tax effect in the present appeal was less than this threshold limit. Consequently, the High Court, in light of the submission regarding the tax effect being below the monetary limit, dismissed the appeal as withdrawn. The court explicitly stated that the substantial questions of law are kept open for determination in an appropriate case. No costs were awarded.
The High Court did not decide the substantial questions of law on merits. Instead, the Revenue brought to the court's notice Circular No.17/2019 dated 08.08.2019 issued by the CBDT. This circular stipulates that appeals shall not be filed or pursued by the Department before the High Court if the tax effect does not exceed Rs.1,00,00,000/-. The learned counsel for the Revenue submitted that the tax effect in these appeals was less than this threshold limit. Consequently, the High Court, in light of the submission regarding the tax effect being below the monetary limit, dismissed the present appeals as withdrawn. The court explicitly stated that the substantial questions of law were kept open for determination in appropriate cases. No costs were awarded.
The High Court did not decide the substantial questions of law on merits. The learned counsel for the Revenue brought to the court's notice CBDT Circular No. 17/2019, which stipulates that appeals shall not be filed or pursued if the tax effect does not exceed Rs. 1,00,00,000/-. It was submitted that the tax effect in these appeals was below this threshold limit. Consequently, the High Court dismissed the present appeals as withdrawn, in light of the circular and the tax effect being less than the monetary limit. The substantial questions of law were left open for determination in appropriate cases. No costs were awarded.
The High Court did not decide the substantial questions of law on merits. Instead, the court took note of the submission by the Revenue regarding CBDT Circular No.17/2019, which sets a monetary threshold of Rs.1,00,00,000/- for filing or pursuing appeals. Since the tax effect in the present appeals was stated to be less than this threshold, the High Court dismissed the appeals as withdrawn. The court explicitly stated that the substantial questions of law were kept open for determination in appropriate cases. No costs were awarded. The ITAT's order was not analyzed or overturned.
The High Court, in light of CBDT Circular No. 17/2019, which mandates that appeals with a tax effect not exceeding Rs. 1,00,00,000/- should not be filed or pursued, dismissed the appeals. The court noted that the tax effect in these appeals was below the stipulated monetary limit. Consequently, the appeals were dismissed as withdrawn. The substantial questions of law were kept open for determination in appropriate future cases. No costs were awarded. The specific findings on the merits of the depreciation on goodwill, the fresh claim during assessment, and the MAT credit carry-forward, as per the ITAT's order, were not adjudicated by the High Court due to the procedural dismissal.
The High Court of Judicature at Madras did not decide the substantial questions of law on merits. The learned counsel for the appellant/Revenue brought to the court's notice Circular No.17/2019 dated 08.08.2019 issued by the Central Board of Direct Taxes. This circular stipulates that appeals shall not be filed or pursued by the Department before the High Court if the tax effect does not exceed Rs.1,00,00,000/-. The Revenue submitted that the tax effect in the present appeal was less than this threshold limit. Consequently, the appeal was dismissed as withdrawn, keeping the substantial questions of law open for determination in an appropriate case. No costs were awarded.
The High Court did not decide the substantial questions of law on their merits. Instead, the appeal was dismissed as withdrawn by the Revenue. This decision was based on the submission by the Revenue that the tax effect in the appeal was less than the monetary limit stipulated in CBDT Circular No. 17/2019. The Court noted that the Circular mandates that appeals shall not be filed or pursued by the Department before the High Court if the tax effect does not exceed Rs. 1,00,00,000/-. Consequently, the appeal was disposed of as withdrawn, with the substantial questions of law left open for determination in an appropriate future case. No costs were awarded.
The High Court noted the submission by the Revenue's Standing Counsel regarding CBDT Circular No. 17/2019. This circular mandates that appeals should not be filed or pursued before the High Court if the tax effect is below Rs. 1,00,00,000/-. The Revenue confirmed that the tax effect in the present appeal was indeed less than this prescribed monetary limit. Consequently, the High Court, in light of this submission and the circular, dismissed the appeal as withdrawn. The substantial question of law was kept open for determination in an appropriate future case. No costs were awarded.
The High Court did not decide the substantial questions of law on their merits. Instead, the Court took note of the CBDT Circular No.17/2019, which sets a monetary limit of Rs. 1,00,00,000/- for filing or pursuing appeals by the Department before the High Court. The learned counsel for the appellant/Revenue submitted that the tax effect in the present appeal was less than this threshold limit. Consequently, the High Court dismissed the appeal as withdrawn, stating that the substantial questions of law remain open for determination in an appropriate case. No costs were awarded. The Tribunal's earlier order deleting the reallocation of R&D expenditure was not disturbed on merits by the High Court.
The High Court did not decide the substantial questions of law on merits. Instead, the Court took note of the submission made by the learned counsel for the appellant/Revenue regarding CBDT Circular No. 17/2019. This circular mandates that appeals shall not be filed or pursued by the Department before the High Court in cases where the tax effect does not exceed Rs. 1,00,00,000/-. As the tax effect in the present appeal was stated to be less than this monetary threshold, the High Court dismissed the appeal as withdrawn. The Court explicitly stated that the substantial questions of law were kept open for determination in an appropriate case. No costs were awarded.
The High Court did not decide the substantial questions of law on merits. Instead, the appeal was dismissed as withdrawn by the Revenue. This decision was based on the submission by the Revenue's counsel that the tax effect in the appeal was less than the monetary limit of Rs. 1,00,00,000/- stipulated in CBDT Circular No. 17/2019 for pursuing appeals before the High Court. The court explicitly stated that the substantial questions of law were kept open for determination in an appropriate case. Therefore, there was no finding on any of the issues raised, nor any reasoning provided by the court concerning the merits of the case. No operative directions were issued regarding the ITAT's order.
The High Court dismissed the appeals as withdrawn. This decision was based on the submission by the Revenue's counsel, referencing Circular No.17/2019 issued by the Central Board of Direct Taxes. This circular stipulates that the Department shall not file or pursue appeals before the High Court if the tax effect does not exceed Rs.1,00,00,000/-. The Revenue submitted that the tax effect in these appeals was below this threshold limit. Consequently, the appeals were dismissed as withdrawn, with the substantial questions of law left open for determination in future appropriate cases. No costs were awarded.
The High Court did not decide the substantial questions of law on merits. Instead, the Court noted the submission by the Revenue's learned Standing Counsel regarding CBDT Circular No. 17/2019. This circular stipulates that appeals shall not be filed or pursued by the Department before the High Court in cases where the tax effect does not exceed Rs. 1,00,00,000/-. The Revenue submitted that the tax effect in the present appeal was less than this stipulated threshold limit. Consequently, in light of the Revenue's submission and the CBDT circular, the High Court dismissed the present appeal as withdrawn. The Court explicitly stated that the substantial questions of law were kept open for determination in an appropriate case. No costs were awarded.
The High Court, in its common judgment, did not decide the substantial questions of law on their merits. Instead, the Court noted the submission by the Revenue's Standing Counsels regarding CBDT Circular No. 17/2019, which mandates that appeals should not be filed or pursued by the Department before the High Court if the tax effect does not exceed Rs. 1,00,00,000/-. The Revenue confirmed that the tax effect in these appeals was less than the stipulated threshold. Consequently, the High Court dismissed the present appeals as withdrawn, while explicitly stating that the substantial questions of law remain open for determination in appropriate cases. No costs were awarded.
The High Court, in light of the submission by the Revenue regarding CBDT Circular No. 17/2019, dismissed the appeal as withdrawn. The circular mandates that appeals shall not be filed or pursued if the tax effect does not exceed Rs. 1,00,00,000/-. The Revenue confirmed that the tax effect in the present appeal was below this monetary limit. Therefore, the appeal was disposed of without a decision on the merits of the substantial questions of law. The court explicitly stated that the substantial questions of law remain open for determination in an appropriate case. No costs were awarded.
The High Court did not decide the substantial questions of law on merits. Instead, based on the submission by the Revenue regarding CBDT Circular No. 17/2019, which mandates that appeals should not be filed or pursued if the tax effect does not exceed Rs. 1,00,00,000, the Court dismissed the appeals. The Court noted that the tax effect in these appeals was below the stipulated threshold. The substantial questions of law were kept open for determination in appropriate cases. No costs were awarded.
The High Court did not decide the substantial questions of law on merits. Instead, the Court took note of CBDT Circular No. 17/2019, which mandates that appeals shall not be filed or pursued by the Department before the High Court if the tax effect does not exceed Rs. 1,00,00,000/-. The Revenue's counsel submitted that the tax effect in the present appeal was less than this monetary limit. Consequently, the High Court dismissed the appeal as withdrawn, stating that the substantial questions of law were kept open for determination in an appropriate case. No costs were awarded. The specific findings of the ITAT on the disallowances under Sections 14A, 115JB, 40(a)(ia), and 40(a)(i) were not adjudicated by the High Court.
The High Court of Judicature at Madras, considering the submission by the Revenue regarding CBDT Circular No.17/2019, which mandates that appeals should not be filed or pursued if the tax effect does not exceed Rs. 1,00,00,000/-, found that the tax effect in this appeal was below the stipulated threshold. Consequently, the Court dismissed the appeal as withdrawn. The substantial questions of law were kept open for determination in an appropriate case. No costs were awarded. The specific findings of the Tribunal on the reallocation of R&D expenditure, which were the subject of the appeal, were not adjudicated upon by the High Court due to the procedural reason of the tax effect being below the monetary limit.
The High Court did not decide the substantial questions of law on merits. Instead, the learned counsel for the Revenue brought to the court's notice CBDT Circular No.17/2019 dated 08.08.2019. This circular stipulates that appeals shall not be filed or pursued by the Department before the High Court if the tax effect does not exceed Rs.1,00,00,000/- (Rupees One Crore). The Revenue submitted that the tax effect in these appeals was below this threshold limit. Consequently, the High Court, in light of the Revenue's submission regarding the tax effect being less than the monetary limit, dismissed the present appeals as withdrawn. The court explicitly stated that the substantial questions of law were kept open for determination in appropriate cases. No costs were awarded.
The High Court did not decide the substantial questions of law on merits. Instead, it noted the submission by the Revenue's counsel regarding CBDT Circular No.17/2019, which sets a monetary limit of Rs.1,00,00,000/- for pursuing appeals before the High Court. As the tax effect in the present appeal was stated to be less than this threshold, the High Court dismissed the appeal as withdrawn. The Court explicitly stated that the substantial questions of law were kept open for determination in an appropriate case. No costs were awarded, and the connected miscellaneous petition was closed.
The High Court dismissed the appeal as withdrawn. The dismissal was based on the submission by the Revenue that the tax effect in the appeal was less than the threshold limit of Rs.1,00,00,000/- stipulated in CBDT Circular No.17/2019. The Court noted that the substantial question of law was kept open for determination in an appropriate case. Therefore, the High Court did not decide the substantial question of law on its merits. No costs were awarded. The operative direction was the dismissal of the appeal.