248 orders · Page 2 of 5
The High Court of Judicature at Madras, in its judgment delivered by the Hon'ble Chief Justice, noted that there was no appearance for the appellant. It further acknowledged the submission of a letter dated 13.08.2025 seeking to list the appeal for withdrawal. The reason provided in the letter was that the appellant had availed the benefits under the "Vivad Se Vishwas Scheme" during the pendency of the appeal and was consequently no longer inclined to press the appeal. In light of this subsequent development and the appellant's expressed wish to withdraw, the Court ordered the appeal to be dismissed as withdrawn. No order as to costs was made. The specific grounds of the original appeal before the ITAT and the substance of the ITAT's order were not discussed or decided by the High Court.
The High Court noted that the appellant had submitted a letter seeking to list the appeal for withdrawal on the ground that they had availed the benefits under the "Vivad Se Vishwas Scheme" during the pendency of the appeal. Consequently, the appellant was no longer inclined to press the appeal. In view of this subsequent development and the appellant's expressed wish to withdraw, the High Court dismissed the appeal as withdrawn. No order as to costs was made. The specific grounds or the merits of the original appeal before the Tribunal were not decided.
The High Court of Judicature at Madras, comprising the Chief Justice and Mr. Justice Sunder Mohan, decided to dismiss the appeal as withdrawn. The reasoning was based on the subsequent development communicated by the appellant via a letter dated 13.08.2025. The appellant had stated that it had availed the benefits under the "Vivad Se Vishwas Scheme" and, as a result, was no longer inclined to pursue the appeal. The Court accepted this submission and, in view of the stated development, passed an order dismissing the appeal as withdrawn. The operative direction was the dismissal of the appeal. No issue was expressly left undecided. The ratio decidendi is that an appeal can be withdrawn if the appellant has subsequently settled the dispute under a beneficial scheme like "Vivad Se Vishwas" and no longer wishes to press the appeal.
The High Court noted that the appellant (assessee) had submitted a letter seeking to list the appeal for withdrawal. The ground for withdrawal was that the appellant had availed the benefits under the 'Vivad Se Vishwas Scheme' during the pendency of the appeal, and therefore, was no longer inclined to press the appeal. Considering this subsequent development and the appellant's request, the High Court dismissed the appeal as withdrawn. No specific issue regarding the merits of the original appeal was decided. The operative direction was to dismiss the appeal as withdrawn. There was no order as to costs.
The High Court, after hearing the parties and considering the Supreme Court's decision in Commissioner of Income Tax-III, Pune vs. Rajasthan & Gujarati Charitable Foundation Poona, decided to answer questions of law Nos. 2 and 3 in favour of the assessee and against the Revenue. The Court found that the Supreme Court's ruling directly addressed the issues concerning the disallowance of depreciation in tax exemption computation under Section 11 of the Act and the impact of the amendment to Section 11(6). The reasoning was that the Supreme Court had held against the Revenue on these points. Consequently, the disallowance of depreciation was deemed incorrect for the assessment years in question. The first question of law was not pressed by the assessee. The appeal was therefore partly allowed, with no order as to costs.
The High Court answered both questions of law in favour of the assessee. Regarding the second question, the Court, following its earlier decision in Commissioner of Income Tax vs. Ashok Leyland Ltd., held that in the case of an assessment under Section 115JA, the deduction claimed by the assessee under Section 80HHC must be worked out on the basis of the adjusted book profit under Section 115JA, and not on the basis of profits computed under the regular provisions of law. As a consequence of this finding, the Court held that the Tribunal was not justified in excluding 90% of duty drawback, labour charges, weighment charges, dividend income, interest income, and profit on sale of assets from the book profits under Section 115JA while computing the deduction under Section 80HHC. The reasoning was that the deduction under Section 80HHC is intrinsically linked to the book profits as adjusted under Section 115JA. The appeal was accordingly allowed, with no order as to costs. No issues were expressly left undecided.
The High Court noted the submission of the Revenue's counsel that the case had a low tax effect. In light of Circular No.05/2024 and Circular No.09/2024, the Revenue expressed its unwillingness to pursue the appeal. Consequently, the High Court dismissed the appeal. The Court explicitly stated that the question of law, though not decided on merits, would be kept open for consideration in an appropriate matter. No order as to costs was made. The judgment does not provide any specific findings on the merits of the original dispute before the ITAT, nor does it detail the reasoning of the ITAT.
The High Court noted the submission of the Revenue's counsel that the case had a low tax effect. In view of Circular No.05/2024 dated 15.03.2024 and Circular No.09/2024 dated 17.09.2024, issued by the Ministry of Finance, Department of Revenue, Central Board of Direct Taxes, the Revenue stated that it did not wish to proceed with the matter. The Revenue also indicated that the question of law could be kept open for consideration in an appropriate matter. Consequently, the High Court dismissed the appeal. No order as to costs was made, and the interim application was closed.
The High Court dismissed the appeal filed by the Revenue. The primary reason for dismissal was the submission by the Revenue's counsel that the case had a low tax effect. Citing Circular No.05/2024 dated 15.03.2024 and Circular No.09/2024 dated 17.09.2024, the Revenue stated its intention not to proceed with the appeal. The Court accepted this submission and accordingly dismissed the appeal. The Court also noted the Revenue's request to keep the questions of law open for consideration in future appropriate matters, but this did not alter the decision to dismiss the present appeal. No order as to costs was made.
The High Court, in its judgment delivered by the Hon'ble Chief Justice, noted the submission of the learned counsel for the Revenue regarding the low tax effect and reliance on CBDT Circulars No. 05/2024 and 09/2024. Consequently, the Revenue expressed its unwillingness to pursue the appeal further. The Court accepted this submission and proceeded to dismiss the appeal. The Court explicitly stated that the questions of law would be kept open for consideration in an appropriate matter. No specific finding was made on the merits of the case, and no operative directions for remand or deletion were issued. The appeal was dismissed on procedural grounds as per the Revenue's request.
The High Court, in view of the submission made by the learned counsel for the Revenue that the case has a low tax effect and that the Revenue does not wish to proceed with the matter in light of Circular No.05/2024 and Circular No.09/2024, dismissed the appeal. The Court noted that the Revenue requested that the questions of law be kept open for consideration in an appropriate matter. The operative direction was that the appeal stands dismissed with no order as to costs. No specific issue was left undecided as the appeal was dismissed on the grounds of low tax effect and the Revenue's decision not to press it.
The High Court, after hearing the counsel for the Revenue, noted the submission that the case had a low tax effect. Relying on Circular No.05/2024 and Circular No.09/2024, the Revenue expressed its unwillingness to pursue the appeal. The Court acknowledged the Revenue's request to keep the questions of law open for future consideration. Consequently, the High Court dismissed the appeal filed by the Revenue. No order as to costs was made. The specific findings of the ITAT or the grounds of appeal are not elaborated upon as the appeal was dismissed on the grounds of low tax effect and the Revenue's decision not to proceed.
The High Court noted the submission by the Revenue's counsel that the case involved a low tax effect. Citing Circular No. 05/2024 and Circular No. 09/2024, the Revenue stated its intention not to proceed with the appeal. The Court acknowledged this position. Consequently, the appeal was dismissed. The Court explicitly stated that the questions of law are kept open for consideration in an appropriate matter, implying no decision on the merits of the case. No specific findings on any issues were made by the High Court, as the dismissal was based on the Revenue's decision not to pursue the appeal.
The High Court held that the appeals should be dismissed. This decision was based on the submission made by the Revenue's counsel that the cases involved a low tax effect. In accordance with Circular No.05/2024 dated 15.03.2024 and Circular No.09/2024 dated 17.09.2024, issued by the Ministry of Finance, Department of Revenue, Central Board of Direct Taxes, the Revenue did not wish to pursue the matter further. The Court accepted this submission and accordingly dismissed the appeals. The questions of law were expressly left open for consideration in an appropriate matter. No order as to costs was made. The operative direction was the dismissal of the appeals.
The High Court noted the submission by the learned counsel for the Revenue that the case has a low tax effect. In light of this submission and in accordance with Circular No.05/2024 and Circular No.09/2024 issued by the Ministry of Finance, Department of Revenue, Central Board of Direct Taxes, the Revenue stated its intention not to proceed with the matter. The Court acknowledged that the questions of law may be kept open for consideration in other matters. Consequently, the appeal filed by the Revenue was dismissed. No specific findings were made on the merits of the case or the issues that might have been raised by the Tribunal's order. The operative direction was the dismissal of the appeal.
The High Court disposed of the appeal in light of its earlier order dated 08.02.2022 in TCA Nos.509 to 511 of 2010, which dealt with similar issues between the same parties for assessment years 1996-97, 1997-98, and 1998-99. The Court upheld the order of remand by the Tribunal. The Assessing Officer was directed to decide the issue, upon remand, strictly in accordance with the law laid down by the Supreme Court in the case of South Indian Bank Ltd. v. Commissioner of Income Tax. The Court noted that all other issues were left open for consideration by the Assessing Officer. No order as to costs was made. The operative direction was to remand the matter to the Assessing Officer for fresh consideration as per the Supreme Court's ruling.
The High Court noted the submission by the Revenue's counsel that the case had a low tax effect. In view of Circular No.05/2024 and Circular No.09/2024, issued by the Ministry of Finance, Department of Revenue, Central Board of Direct Taxes, the Revenue stated it did not wish to proceed with the appeal. Consequently, the High Court dismissed the appeal. The questions of law were expressly kept open for consideration in an appropriate matter. No order as to costs was made, and the connected miscellaneous petition was closed.
The Revenue, through its counsel, submitted that the case had a low tax effect and, in light of CBDT Circulars No. 05/2024 and 09/2024, did not wish to proceed with the appeal. The Revenue requested that the questions of law be kept open for consideration in an appropriate future matter. Consequently, the High Court dismissed the appeal. No decision was made on the merits of the case. The operative direction was the dismissal of the appeal, with no order as to costs.
The High Court, upon hearing the learned counsel for both the appellant/Revenue and the respondent/assessee, noted the submission by the Revenue that the case had a low tax effect. In light of this submission and the Circular No.05/2024 dated 15.03.2024 and Circular No.09/2024, dated 17.09.2024, issued by the Ministry of Finance, Department of Revenue, Central Board of Direct Taxes, the Revenue expressed its unwillingness to proceed with the appeal. The Court accepted this position and accordingly dismissed the appeal. The questions of law were expressly left open for consideration in an appropriate matter. No order as to costs was made.
The High Court noted the submission of the Revenue that the case involves a low tax effect. Consequently, in light of Circular No.05/2024 and Circular No.09/2024, the Revenue expressed its unwillingness to pursue the appeal further. The Court accepted this submission and accordingly dismissed the appeal. The Court explicitly stated that the questions of law proposed may be kept open for consideration in an appropriate matter. No specific findings were made on the merits of the original dispute, as the appeal was disposed of on procedural grounds related to tax effect and departmental circulars. The operative direction was the dismissal of the appeal.
The High Court, upon hearing the learned counsel for both the appellant/Revenue and the respondent/assessee, noted the submission by the Revenue that the case involved a low tax effect. Citing Circular No.05/2024 and Circular No.09/2024, the Revenue indicated its decision not to pursue the appeal further, though it sought to keep the question of law open. Consequently, the High Court dismissed the appeal. No order as to costs was made. The specific findings of the ITAT or the substantive legal questions that were to be decided by the High Court are not elaborated upon as the appeal was disposed of on the basis of the Revenue's submission and the low tax effect circulars.
The High Court held that in view of the submissions made by the learned counsel for the appellant/Revenue, who fairly submitted that it was a case with a low tax effect and that the Revenue did not wish to proceed with the matter in light of Circular No.05/2024 and Circular No.09/2024, the appeal stands dismissed. The Court noted that the questions of law would be kept open for consideration in an appropriate matter. No order as to costs was made. The operative direction was the dismissal of the appeal.
The High Court, in its decision delivered by the Hon'ble Chief Justice, noted the submission by the Revenue that the case had a low tax effect. Citing Circular No. 05/2024 and Circular No. 09/2024, the Revenue stated its intention not to proceed with the appeal. The Court accepted this submission. Consequently, the appeal was dismissed. The Court also noted that the questions of law were to be kept open for consideration in an appropriate matter. No specific findings were made on the merits of the case, and no operative directions were issued beyond the dismissal of the appeal. The issue of costs was also addressed, with no order as to costs.
The High Court noted the submission made by the learned counsel for the appellant that the appellant had availed the "Direct Tax Vivad Se Vishwas Scheme, 2024" for settlement of the litigation. Consequently, the appellant did not wish to press the appeal. Placing on record this statement, the Tax Case Appeal was dismissed as not pressed. No order as to costs was made. The specific grounds of appeal and the merits of the original dispute were not adjudicated upon as the appeal was withdrawn by the appellant.
The High Court held that the findings of the CIT(A) and the ITAT were based on facts. The substantial questions of law proposed by the assessee were found to be factual in nature and did not raise any question of law. The Court noted that the new ground regarding the husband's illness was not raised before the CIT(A) or the ITAT. Therefore, the Court was not inclined to entertain the appeal. The appeal was dismissed. No issue was expressly left undecided.
The High Court of Judicature at Madras dismissed the appeal. The Court noted the submission by the learned counsel for the appellant (revenue) that the issue was no longer res integra and that an identical issue had been decided in TCA No.138 of 2025, which was dismissed by a judgment dated July 31, 2025. Based on this submission and the precedent, the Court dismissed the present appeal in terms of the judgment passed in TCA No.138 of 2025. No order as to costs was made. The connected civil miscellaneous petition (CMP No.19879 of 2025) was closed. The specific findings of the ITAT or the ratio decidendi of the dismissed appeal were not elaborated upon, as the High Court's decision was based on the principle of stare decisis and the revenue's concession.
The High Court held that the substantial questions of law framed by the appellant did not arise for consideration and therefore did not need to be answered. The Court noted that the appellant's counsel candidly admitted that notices were served through electronic mode and that the mode of service was not assailed. The judgment also highlighted that the appellant had remained absent before the CIT (Appeals) despite opportunities and that the ITAT's order recorded multiple notices issued. Consequently, the Court found the appeal to be without merit and dismissed it. No specific findings were made on the merits of the grounds raised by the appellant, as the appeal was dismissed on procedural grounds.
The High Court recorded the submission of the Revenue's counsel that the appeal was not to be pursued for the assessment period 2008-09 due to low tax effect, as per Circular No. 9 of 2024. Consequently, the Court dismissed the tax case appeal as withdrawn. The Court explicitly stated that the question of law remains open to be decided in an appropriate future matter. No costs were awarded.
The High Court held that the Commissioner's invocation of Section 263 was not justified. The Court distinguished between a 'lack of inquiry' and an 'inadequate inquiry'. It found that there was an inquiry, even if it could be considered inadequate, and the Commissioner could not invoke Section 263 merely because he had a different opinion. The assessment order could not be termed erroneous simply because the Commissioner felt it should have been written more elaborately. The Court referred to the principles laid down in CIT vs. Sunbeam Auto Ltd. and CIT vs. Gabriel India Ltd., stating that the Commissioner's power under Section 263 is not arbitrary and must be based on materials on record. The Court concluded that the present case was one of alleged inadequate inquiry rather than a lack of inquiry or material, and therefore, the Commissioner's interference was unwarranted. The first substantial question of law was answered in favour of the assessee. Consequently, the other questions were rendered academic and not answered. The appeal was allowed.
The High Court noted that the appellant's counsel, upon instructions, sought to withdraw the appeals. Consequently, the Court ordered the dismissal of these appeals as withdrawn. No order as to costs was made, and the interim applications filed in these appeals were also closed. The judgment does not record any decision on the merits of the original dispute that led to the ITAT orders.
The High Court noted the submission made by the learned counsel for the Revenue that the case had a low tax effect. Consequently, in view of the CBDT Circulars No.05/2024 and 09/2024, the Revenue expressed its unwillingness to pursue the appeal. The Court accepted this submission and decided to dismiss the appeal. The Revenue requested that the questions of law be kept open for future consideration, which the Court implicitly acknowledged by dismissing the appeal on the grounds of low tax effect rather than on merits. No specific findings were made on the substantive issues that might have been raised in the appeal. The operative direction was the dismissal of the appeal, with no order as to costs.
The High Court noted the submission by the Revenue's counsel that the case had a low tax effect. In light of Circular No.05/2024 and Circular No.09/2024, the Revenue stated its intention not to pursue the appeal further. Consequently, the High Court dismissed the appeal. The court explicitly mentioned that the questions of law proposed by the Revenue would be kept open for consideration in an appropriate matter in the future. No decision was made on the merits of the case. The operative direction was the dismissal of the appeal.
The High Court noted the submission of the Revenue that the case had a low tax effect and, in accordance with the CBDT Circulars No.05/2024 and 09/2024, the Revenue did not wish to pursue the appeal. Consequently, the High Court dismissed the appeal. The Court also stated that the questions of law raised in the appeal were to be kept open for consideration in an appropriate future matter. No order as to costs was made. The Tribunal's order dated 16.02.2017, which was under challenge, is not discussed on its merits.
The High Court noted the submission made by the learned counsel for the Revenue that the case has a low tax effect. In light of Circular No.05/2024 and Circular No.09/2024, the Revenue expressed its unwillingness to proceed with the appeal. The Court acknowledged this submission and, based on it, dismissed the appeal. The Court explicitly stated that the questions of law proposed in the appeal would be kept open for consideration in an appropriate case. No specific findings were made on the merits of the ITAT's order, as the appeal was disposed of on the basis of the Revenue's submission regarding low tax effect and the relevant circulars. The operative direction was the dismissal of the appeal.
The High Court noted the submission made by the learned counsel for the Revenue that the case had a low tax effect. In view of Circular No.05/2024 and Circular No.09/2024, the Revenue expressed its disinclination to pursue the appeal. Consequently, the High Court placed on record the Revenue's submission and dismissed the appeal. The Court stated that the proposed questions of law would be kept open for consideration in an appropriate case. No specific findings were made on the merits of the case, and no amount in dispute was mentioned. The operative direction was the dismissal of the appeal.
The High Court noted the submission of the learned counsel for the Revenue that the case had a low tax effect. In view of the Circular No.05/2024 dated 15.03.2024 and Circular No.09/2024 dated 17.09.2024, issued by the Ministry of Finance, Department of Revenue, Central Board of Direct Taxes, the appellant/Revenue stated it did not wish to proceed with the matter. The Court accepted this submission and accordingly dismissed the appeal. The Court also noted that the questions of law proposed may be kept open for consideration in an appropriate case. No specific finding was given on the merits of the case, as the appeal was dismissed based on the Revenue's submission regarding low tax effect and the relevant circulars.
The High Court noted the submission made by the learned counsel for the Revenue that the case has a low tax effect. In light of Circular No. 05/2024 and Circular No. 09/2024, the Revenue expressed its unwillingness to pursue the appeal. Consequently, the High Court dismissed the appeal. The Court stated that the questions of law proposed by the Revenue may be kept open for consideration in an appropriate case. No order as to costs was made. The specific findings of the ITAT or the High Court on the merits of the case are not recorded as the appeal was dismissed on the ground of low tax effect and the Revenue's decision not to proceed.
The High Court noted the submission by the Revenue's counsel that the case had a low tax effect and, in view of Circular No.05/2024 and Circular No.09/2024, the Revenue did not wish to proceed with the appeal. The Court accepted this submission and accordingly dismissed the appeal. The Court explicitly stated that the questions of law proposed by the Revenue could be kept open for consideration in an appropriate case. No specific finding was made on the merits of the ITAT's order. The operative direction was the dismissal of the appeal, with no order as to costs.
The High Court noted that the learned counsel for the appellant sought to withdraw the appeal. Consequently, the High Court dismissed the appeal as withdrawn. There was no order as to costs. No specific findings were made on the merits of the case as the appeal was withdrawn by the appellant. The operative direction was to dismiss the appeal as withdrawn.
The High Court, considering the submissions made by the learned counsel for the Revenue, noted that the Revenue itself submitted that the case has a low tax effect. In light of Circular No.05/2024 dated 15.03.2024 and Circular No.09/2024, dated 17.09.2024, issued by the Ministry of Finance, Department of Revenue, Central Board of Direct Taxes, the Revenue expressed its unwillingness to proceed with the appeal. The Court accepted this submission and accordingly dismissed the appeal. The question of law was expressly kept open for consideration in an appropriate matter. No order as to costs was made.
The High Court noted the submission by the learned counsel for the Revenue that the case had a low tax effect. Citing Circular No.05/2024 and Circular No.09/2024, the Revenue expressed its intention not to proceed with the appeal, while requesting that the question of law be preserved for future consideration. In light of this submission, the High Court decided to dismiss the appeal. The court stated that there would be no order as to costs. No specific issue was decided on merits, and the appeal was disposed of based on the Revenue's submission regarding low tax effect and the relevant circulars.
The High Court did not decide the appeal on its merits. The learned counsel for the appellant (assessee) sought to withdraw the appeal due to subsequent developments. The respondent (revenue) did not oppose this request. Consequently, the High Court dismissed the petition as withdrawn. No order was made as to costs. The judgment does not record any finding on the issues that were before the Tribunal, nor does it provide any reasoning or ratio decidendi for a future case. The operative direction was solely to dismiss the appeal as withdrawn.
The High Court held that the questions of law proposed by the appellant in the present appeal have already been answered by this Court in an earlier judgment. Specifically, the Court referred to its decision in the case of Commissioner of Income Tax v. Sutherland Global Services Inc., delivered on 10.6.2025 in T.C.A.Nos.80, 81 and 82 of 2025. Based on this submission by the Revenue's counsel, the High Court found no reason to re-examine the same issues. Therefore, the appeal was dismissed. The ratio decidendi is that if the issues raised in an appeal have been conclusively decided by the same court in a prior case, a subsequent appeal raising identical issues can be disposed of summarily based on the earlier decision, especially when conceded by the appellant.
The High Court of Judicature at Madras, comprising the Chief Justice and Mr. Justice Sunder Mohan, held that the questions of law proposed by the appellant (revenue) in the present appeal have already been answered by this Court in a previous judgment. Specifically, the Court referred to its decision in Commissioner of Income Tax v. Sutherland Global Services Inc., dated June 10, 2025, in T.C.A.Nos.80, 81 and 82 of 2025. Based on this submission by the revenue's counsel, the Court found no necessity to adjudicate the present appeal independently. The appeal was accordingly dismissed. No order as to costs was made, and the interim application stood closed.
The High Court held that the appeal did not present any substantial question of law for decision. This conclusion was reached because the Revenue's counsel conceded that the issues and questions of law raised in the present appeal had already been decided against the Revenue and in favour of the assessee in the case of Commissioner of Income-tax, International Taxation vs. Sutherland Global Services Inc., [(2025) 175 taxmann.com 897 (Madras)], decided on 10.06.2025. Consequently, the appeal was dismissed at the admission stage itself. No order as to costs was made. The interim application was also disposed of.
The High Court held that the appeal filed by the Revenue was not maintainable because it did not meet the monetary limit prescribed by the CBDT Circular No.09/2024. The learned counsel for the Revenue fairly conceded this point. Consequently, the appeal was closed. The reasoning is based on the binding nature of the CBDT circular regarding monetary limits for appeals. The ratio decidendi is that appeals filed by the Revenue below the stipulated monetary threshold are liable to be dismissed or closed without a decision on merits. The operative direction was to close the appeal and consequently, the related miscellaneous applications (CMP Nos.10843 and 11154 of 2025). No issue was expressly left undecided.
The High Court noted that the learned counsel for the petitioner sought leave to withdraw the petition. Consequently, the Court dismissed the petition as withdrawn. There were no specific issues decided on merits by the High Court, and therefore, no findings or reasoning were provided on any substantive legal or factual matter. The operative direction was solely to dismiss the petition as withdrawn, with no order as to costs. No issues were expressly left undecided as the matter was disposed of on procedural grounds.
The High Court noted that the counsel for the appellant (Revenue) stated that the monetary limit involved in the appeals was below the prescribed limits in recent circulars from the Ministry of Finance. Consequently, the counsel had instructions to withdraw the appeals. The withdrawal was explicitly stated to be due to the monetary limit and without conceding the Department's stand. Therefore, the Court ordered the appeals to be dismissed as withdrawn. No order as to costs was made. The judgment does not record any decision on the merits of the original appeals before the ITAT.
The Tribunal noted that the revenue's counsel, Mr. Narayanasamy, stated that the monetary limit involved in the appeal was below the prescribed limits in recent circulars (Circular No.05/2024 and Circular No.09/2024). Acting on instructions, the counsel sought to withdraw the appeal. The counsel clarified that the withdrawal was solely based on the monetary limit and did not involve conceding the Department's stand on the merits of the case. Consequently, the Tribunal dismissed the appeal as withdrawn, with no order as to costs. The principle derived is that appeals falling below the stipulated monetary limits, as per CBDT circulars, can be withdrawn by the revenue.
The High Court noted that the counsel for the appellant (revenue) stated that the monetary limit involved in the appeal was below the limits prescribed by Circular No.05/2024 and Circular No.09/2024. Consequently, the counsel, acting on instructions, sought to withdraw the appeal. The court was informed that the withdrawal was based on the monetary limit and did not concede the Department's position. Therefore, the appeal was dismissed as withdrawn. No order as to costs was made.