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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The High Court dismissed the appeals as withdrawn. The dismissal was based on the submission by the Revenue that the tax effect in these appeals was less than the threshold limit stipulated in CBDT Circular No. 17/2019. The Court noted that the appeals were being dismissed in light of this submission and the circular. The substantial questions of law were kept open for determination in appropriate cases. No costs were awarded. The operative direction was to dismiss the appeals as withdrawn and close the connected miscellaneous petition.
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 Consequently, the High Court, in light of this submission and the circular, dismissed the appeal as withdrawn.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The High Court dismissed the appeal as withdrawn. The dismissal was based on the submission by the Revenue's counsel regarding CBDT Circular No. 17/2019, which sets a monetary limit for filing and pursuing appeals before the High Court. The Revenue stated that the tax effect in the present appeal was less than the stipulated threshold of Rs. 1,00,00,000/-. Consequently, the appeal was disposed of without delving into the merits of the substantial questions of law framed earlier. 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 considered 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/-. The Revenue stated that the tax effect in this particular appeal falls below this prescribed monetary limit. Consequently, in light of the circular and the submission regarding the tax effect, the High Court dismissed the present appeal as withdrawn. The substantial question of law was kept open for determination in an appropriate case. No costs were awarded.
The High Court dismissed the appeals as withdrawn. The Court noted the submission made by the learned counsel for the appellant/Revenue regarding Circular No.17/2019 issued by the Central Board of Direct Taxes. 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/-. The Revenue confirmed that the tax effect in these appeals was less than the stipulated threshold limit. Consequently, in light of this submission and the circular, the appeals were dismissed 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 dismissed the appeal as withdrawn. This decision was based on 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 less than this monetary limit. Consequently, the Court found it appropriate to dismiss the appeal as withdrawn. The substantial questions of law were kept open for determination in an appropriate case. No costs were awarded. The judgment does not provide findings or reasoning on the merits of the five substantial questions of law that were admitted.
The High Court dismissed the appeals as withdrawn. This decision was based on the submission by the Revenue that the tax effect in these appeals was less than the monetary limit stipulated in CBDT Circular No.17/2019. 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 substantial question of law, which concerned the deductibility of foreign exchange expenditure from total turnover for Section 10AA computation, was not adjudicated on its merits. The court explicitly stated that the substantial question of law was kept open for determination in appropriate cases. 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 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 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/-. The Court noted that the tax effect in this particular appeal was below this threshold. 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 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.
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 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 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 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 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 filed the necessary declarations, which were accepted, and an order for full and final settlement of tax arrears was issued by the Income Tax Department on 05.04.2021. In view of this subsequent development, the Court was of the opinion that nothing further survived for adjudication in the appeal. Accordingly, the Tax Case Appeal was disposed of based on the submission made by the learned counsel for the appellant/Revenue. The Court did not decide on the merits of the substantial questions of law framed at the time of admission.
The High Court, in its judgment delivered by R. Mahadevan, J., noted that the learned counsel for the appellant/Revenue brought to its 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 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 question of law was kept open for determination in an appropriate case. No costs were awarded.
The High Court dismissed the appeals as withdrawn. The 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. As the tax effect in these appeals was stated to be less than this threshold limit, the appeals were dismissed in light of the circular. 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 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 filed necessary declarations, which were accepted, and Form 5 / order for full and final settlement of tax arrears was issued by the Income Tax Department on 20.04.2021. In view of this subsequent development, the High Court was of the opinion that nothing further survived for adjudication in the appeal. Consequently, the Tax Case Appeal was disposed of. The court did not provide findings on the substantial questions of law as the matter was settled under the Vivad Se Vishwas Act.
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. The assessee filed necessary declarations, which were accepted, and a Form 5 order for full and final settlement of tax arrears was issued by the Income Tax Department on 19.04.2021. In view of this subsequent development, the High Court was of the opinion that nothing further survived for adjudication in the appeal. Consequently, the Tax Case Appeal was disposed of. The court did not decide on the merits of the substantial questions of law raised.
The High Court held that in view of the subsequent development where the assessee had availed the benefit of the Direct Tax Vivad Se Vishwas Act, 2020, and a full and final settlement of tax arrears was reached, nothing further survived for adjudication in the appeal. The Court recorded the submission made by the learned counsel for the appellant/Revenue. Consequently, the Tax Case Appeal was disposed of. The Court did not decide the substantial questions of law on merits. The operative direction was to dispose of the appeal as settled.
The High Court noted that the Revenue's counsel submitted that the assessee had availed the benefit of the Direct Tax Vivad Se Vishwas Act, 2020, and filed declarations, which were accepted, leading to a full and final settlement of tax arrears. Consequently, the Revenue argued that nothing remained for adjudication in the appeal. In light of this submission, the High Court found that the appeal had become infructuous. The Court did not delve into the merits of the substantial questions of law framed at the time of admission. The operative direction was to dismiss the appeal as withdrawn.
The High Court noted that during the pendency of the Tax Case Appeal, the assessee had availed the benefits under the Direct Tax Vivad Se Vishwas Act, 2020. The assessee filed the necessary declarations, which were accepted, and the Income Tax Department issued a Form 5 order for full and final settlement of tax arrears on 28.10.2021. In view of this subsequent development, the High Court was of the opinion that nothing further survived for adjudication in the appeal. Consequently, the Tax Case Appeal was disposed of based on the submission made by the learned counsel for the appellant/Revenue. No costs were awarded. The specific questions of law were not decided on merits.
The High Court dismissed the appeal as withdrawn. The dismissal was based on 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. Since the tax effect in the present appeal was stated to be less than this threshold limit, the appeal was not pressed on merits. The Court explicitly stated that the substantial question of law is kept open for determination in an appropriate case. No costs were awarded.
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 this particular appeal falls below this monetary threshold. In light of this submission by the Revenue, the High 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 decide the substantial questions of law on their merits. Instead, the Court noted the submission by the Revenue's counsel regarding CBDT Circular No. 17/2019, which mandates that appeals should not be filed or pursued if the tax effect is below Rs. 1,00,00,000/-. The Revenue stated that the tax effect in the present appeal was less than this prescribed monetary limit. Consequently, the High Court dismissed the appeal as withdrawn, explicitly stating that the substantial questions of law were kept open for determination in an appropriate case. 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, noted that the tax effect in these appeals was less than the monetary limit imposed by the circular. Consequently, the appeals were dismissed 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 provide any findings or reasoning on the merits of the substantial questions of law raised, as the appeals were disposed of on the basis of the circular and the tax effect.
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 filed the necessary declarations, which were accepted, and a Form 5 order for full and final settlement of tax arrears was issued by the Income Tax Department on October 28, 2021. Both the learned counsel for the appellant (Revenue) and the respondent (assessee) fairly conceded that in view of this subsequent development, nothing survives for adjudication in the appeal. Consequently, the High Court was of the opinion that the appeal stood disposed of. No costs were awarded. The specific questions of law raised by the Revenue were not adjudicated on merits.
The High Court did not decide the substantial questions of law on merits. The Revenue brought to the court's notice CBDT Circular No.17/2019, 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/-. The Revenue submitted that the tax effect in these appeals was less than this threshold limit. Consequently, the High Court dismissed the present appeals as withdrawn, in light of the Revenue's 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, in light of the submission by the Revenue's counsel regarding CBDT Circular No. 17/2019, which sets a monetary threshold of Rs. 1,00,00,000/- for pursuing appeals before the High Court, noted that the tax effect in the present appeal was less than this limit. Consequently, the 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 did not decide the merits of the substantial questions of law raised.
The High Court did not decide the substantial questions of law on their merits. Instead, the 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. As the tax effect in the present appeal was stated to be less than this threshold, the 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 of Judicature at Madras, in light of the submission made by the learned counsel for the appellant/Revenue regarding CBDT Circular No.17/2019, dismissed the present appeal. The circular stipulates that appeals shall not be filed or pursued by the Department before the High Court where the tax effect does not exceed Rs.1,00,00,000/-. The Revenue confirmed that the tax effect in this appeal was less than the stipulated threshold limit. Consequently, the appeal was dismissed 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. The learned counsel for the appellant/Revenue brought to the court's notice Circular No.17/2019 dated 08.08.2019 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 these appeals was less than this threshold limit. Consequently, the High Court dismissed the present appeals as withdrawn, explicitly stating that the substantial questions of law are 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 appellant/Revenue brought to the notice of the Court 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 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 dismissed the appeals as withdrawn. This decision was based on a submission by the Revenue's counsel, referencing Circular No. 17/2019 dated 08.08.2019 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 less than this threshold limit. Consequently, the High Court dismissed the appeals as withdrawn, explicitly stating that the substantial questions of law were kept open for determination in appropriate cases. No costs were awarded, and the connected miscellaneous petition was closed. The specific findings of the ITAT on the disallowance under Section 14A were not adjudicated upon by the High Court.
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 regarding CBDT Circular No.17/2019, which mandates that appeals should not be filed or pursued if the tax effect is below Rs.1,00,00,000/-. The Revenue stated that the tax effect in the present appeal was less than this monetary limit. Consequently, the appeal was disposed of as withdrawn, with the substantial questions of law left open for determination in an appropriate case. No costs were awarded.
The High Court dismissed the appeals as withdrawn. This decision was based on 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/-. The learned counsel for the Revenue brought to the court's notice that the tax effect in these appeals was less than the stipulated threshold limit. Consequently, the appeals were dismissed as withdrawn, with the substantial questions of law left open for determination in appropriate cases. No costs were awarded. The operative direction is the dismissal of the appeals as withdrawn.
The High Court did not adjudicate on the substantial questions of law. It 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 obtained a full and final settlement of tax arrears. This fact was conceded by the Revenue. Consequently, the High Court was of the opinion that nothing further survived for adjudication in the appeal. The appeal was disposed of based on this subsequent development, without delving into the merits of the ITAT's order or the substantial questions of law framed earlier. No costs were awarded. The specific findings of the ITAT on the four issues were not discussed or affirmed by the High Court.
The High Court, in light of the CBDT Circular No. 17/2019, which sets a monetary threshold for filing and pursuing appeals before the High Court (Rs. 1,00,00,000/-), noted that the tax effect in the present appeal was below this limit. Consequently, the Revenue's counsel submitted that the appeal should be dismissed as withdrawn. The Court accepted this submission and 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 Tribunal on the nature of the hospitality expenses as accrued liability and the reasoning for deleting the addition were not re-examined by the High Court due to the withdrawal of the appeal.
The High Court considered 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/-. The Revenue stated that the tax effect in this particular appeal was less than the specified threshold limit. In light of this submission, the Court found that the appeal, having a tax effect below the monetary limit, was to be dismissed 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 light of the submission made by the learned counsel for the appellant/Revenue regarding CBDT Circular No. 17/2019, dismissed the present appeals. The court noted that the tax effect in these appeals was less than the monetary limit imposed by the circular. Consequently, the appeals were dismissed 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, 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 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 below this threshold limit. Consequently, the High Court dismissed the appeals as withdrawn, stating that the substantial questions of law were kept open for determination in appropriate cases. No costs were awarded.
The High Court noted that the Revenue, through its counsel, brought to its attention CBDT Circular No. 17/2019. This 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/-. The Revenue submitted that the tax effect in the present appeal falls below this stipulated monetary limit. In light of this submission and the circular, the High Court found no reason to proceed with the determination of the substantial questions of law. The appeal was accordingly dismissed as withdrawn, with the court explicitly stating that the substantial questions of law remain open for determination in an appropriate future 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 pursuing appeals before the High Court. The counsel stated that the tax effect in the present appeal was below this threshold. Consequently, the High Court, in light of this submission and the circular, 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 decision was made on the merits of the reassessment proceedings or the classification of interest income. The operative direction was the dismissal of the appeal as withdrawn.
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. The assessee filed necessary declarations, which were accepted, and a Form-5 order for full and final settlement of tax arrears was issued by the Income Tax Department on 30.10.2021. This subsequent development was fairly conceded by the learned Standing Counsel for the Revenue. In view of this settlement, the Court was of the opinion that nothing further survived for adjudication in the appeal. Therefore, the appeal was disposed of based on the settlement reached under the Vivad Se Vishwas Act, without deciding the substantial questions of law on merits. No costs were awarded.
The High Court dismissed the appeal as withdrawn. The dismissal was based on Circular No. 17/2019 dated August 8, 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/- (Rupees One Crore). The learned Standing Counsel for the appellant/Revenue brought to the court's notice that the tax effect in this particular appeal was less than the threshold limit prescribed by the circular. 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 High Court, in light of the submission by the Revenue regarding 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/-, noted that the tax effect in the present appeals was less than the threshold limit. Consequently, the Court dismissed the appeals as withdrawn. The substantial questions of law were kept open for determination in appropriate cases. No costs were awarded, and connected miscellaneous petitions were closed. The Tribunal's decision on the classification of income from share transactions as short-term capital gains or business income was not adjudicated upon by the High Court due to the withdrawal of the appeals.
The High Court dismissed the appeals as withdrawn. The dismissal was based on the submission by the Revenue's 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 less than Rs.1,00,00,000/-. The Revenue stated that the tax effect in these appeals was below this monetary limit. Consequently, the High Court, in light of this submission and the circular, 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 High Court noted the submission by the Revenue's Standing Counsels 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 less than this stipulated threshold. Consequently, the High Court dismissed the appeal as withdrawn, without delving into the merits of the substantial questions of law. 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 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 Revenue contended that the tax effect in the present appeals was below this monetary limit. In light of this submission, the Court dismissed the present appeals as withdrawn. The substantial questions of law were kept open for determination in appropriate cases. No costs were awarded.