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The High Court dismissed the appeal as withdrawn, granting the revenue the liberty to file an application for revival of the appeal as prayed for. The Court clarified that the withdrawal of the appeal by the revenue would not be construed as an affirmation of the ITAT's order on merits. Furthermore, the legal issue, as claimed by the revenue, was left open to be adjudicated in an appropriate future case. The delay of 55 days in refiling the appeal was condoned.
The High Court dismissed the appeal as withdrawn. It granted the revenue the liberty to file an application for revival of the appeal as prayed for. The Court clarified that the withdrawal of the appeal by the revenue would not be considered an affirmation of the Tribunal's order on merits. Furthermore, the legal issue claimed by the revenue was left open to be adjudicated in an appropriate case. The Court did not decide the merits of the case.
The High Court dismissed the appeal as withdrawn. The court granted liberty to the revenue to file an application for revival of the appeal as prayed for. It was clarified that the withdrawal of the appeal by the revenue would not be considered an affirmation of the Tribunal's order on merits. Furthermore, the legal issue claimed by the revenue was left open to be adjudicated in an appropriate case. The court did not decide the merits of the case.
The High Court dismissed the appeal as withdrawn with liberty granted to the revenue to file an application for revival of the appeal as prayed for. The Court clarified that the withdrawal of the appeal by the revenue would not be considered an affirmation of the Tribunal's order on merits. Furthermore, the legal issue, as claimed by the revenue, was left open to be adjudicated in an appropriate case. No specific finding was given on the merits of the case as the appeal was withdrawn.
The High Court dismissed the appeal as withdrawn, granting the revenue liberty to file an application for revival of the appeal as prayed for. The Court clarified that the withdrawal of the appeal by the revenue would not be considered an affirmation of the Tribunal's order on merits. Furthermore, the legal issue claimed by the revenue was left open to be adjudicated in an appropriate case. The Court did not decide the merits of the case.
The High Court dismissed the appeal as withdrawn, granting the revenue the liberty to file an application for revival of the appeal as prayed for. The Court clarified that the withdrawal of the appeal by the revenue would not be considered an affirmation of the ITAT's order on merits. Furthermore, the legal issue, as claimed by the revenue, was left open to be adjudicated in an appropriate future case. The operative direction was the dismissal of the appeal with liberty to revive.
The High Court dismissed the appeal as withdrawn, granting the revenue the liberty to file an application for revival of the appeal as prayed for. The Court clarified that the withdrawal of the appeal by the revenue would not be considered an affirmation of the Income Tax Appellate Tribunal's order on merits. Furthermore, the legal issue, as claimed by the revenue, was left open to be adjudicated in an appropriate case. No specific findings on the merits of the case were made.
The High Court allowed the application for condonation of delay in refiling the appeal. Subsequently, the Court dismissed the appeal as withdrawn, as stated by the learned counsel for the revenue, who had instructions to withdraw the appeal in view of CBDT Circular No. 03/2018 due to the tax effect of ₹44,35,373/-. The Court granted liberty to the revenue to file an application for revival of the appeal as prayed for. It was clarified that the withdrawal of the appeal by the revenue would not be construed as an affirmation of the ITAT's order on merits. Furthermore, the legal issue claimed by the revenue was left open to be adjudicated in an appropriate case.
The High Court dismissed the appeal as withdrawn, granting the revenue the liberty to file an application for revival of the appeal as prayed for. The Court clarified that the withdrawal of the appeal by the revenue would not be considered an affirmation of the Tribunal's order on merits. Furthermore, the legal issue, as claimed by the revenue, was left open to be adjudicated in an appropriate future case. The operative direction was the dismissal of the appeal as withdrawn with liberty granted.
The High Court decided that the substantial question of law regarding the surcharge (Question 1) was already answered against the revenue by this Court in ITA No. 209 of 2014. For the remaining questions (2, 3, and 4) concerning the disallowance under Section 40(a)(ia) for non-deduction of TDS on wheeling/transmission charges and SLDC payments, the Court set aside the orders of the lower authorities. The matter was remitted back to the Assessing Officer (AO) for a fresh decision. This decision was based on the Supreme Court's observations in CIT Vs. Bharti Cellular Limited, which emphasized the need to examine whether human intervention was involved in the services provided, requiring technical data and potentially expert evidence. The AO was directed to examine a technical expert and also consider the applicability of the Provisos to Sections 201(1) and 201(1A) retrospectively, as urged by the assessee. The AO was also permitted to consider the element of income in the transaction. The Tribunal's order was set aside as it did not record independent findings on the element of income.
The High Court, setting aside the orders of the lower authorities, remitted the matter back to the Assessing Officer for a fresh examination. The Court noted that the primary basis for classifying services under Section 194J as 'technical services' by the Supreme Court in Bharti Cellular Limited was the involvement of human intervention, requiring examination of technical data. The High Court observed that it was not discernible from the orders of the authorities below whether there was any human intervention in the services provided. Therefore, the AO is directed to examine this aspect afresh, considering the observations in Bharti Cellular Limited. Additionally, the AO shall examine the applicability of the Provisos inserted in Sections 201(1) and 201(1A) by the Finance Act, 2012, retrospectively, as urged by the assessee. The AO is also permitted to consider the element of income in the transaction before passing a fresh order.
The High Court decided the substantial questions of law accordingly. For Ground No. 1, the Court noted that questions (i) and (ii) were answered against the revenue in view of this Court's decision in ITA No. 258 of 2014 and ITA No. 209 of 2014. For Ground No. 2, concerning the disallowance under Section 40(a)(ia) for non-deduction of TDS on wheeling/transmission charges, the Court, while setting aside the orders of the lower authorities, remitted the matter back to the Assessing Officer (AO). This was done in light of the Supreme Court's observations in CIT vs. Bharti Cellular Limited, which emphasized the need to examine whether human intervention was involved in the services provided. The AO was directed to examine this aspect afresh, potentially with the assistance of a technical expert, and also to consider the applicability of the Provisos inserted in Sections 201(1) and 201(1A) by the Finance Act, 2012 retrospectively. The AO was also permitted to consider the element of income in the transaction. The appeal was disposed of in this manner.
The High Court allowed the application for withdrawal of the appeal. The appeal was dismissed as withdrawn with liberty granted to the revenue to file an application for revival of the appeal as prayed for. The Court clarified that the withdrawal of the appeal by the revenue would not be considered an affirmation of the ITAT's order on merits. Furthermore, the legal issue claimed by the revenue was expressly left open to be adjudicated in an appropriate case. The operative direction was the dismissal of the appeal as withdrawn with liberty.
The High Court allowed the application for withdrawal of the appeal. The appeal was dismissed as withdrawn with liberty granted to the revenue to file an application for revival of the appeal as prayed for. The Court clarified that the withdrawal of the appeal by the revenue would not be construed as an affirmation of the Tribunal's order on merits. Furthermore, the legal issue, as claimed by the revenue, was expressly left open to be adjudicated in an appropriate future case. No specific finding was given on the merits of the case, as the appeal was withdrawn by the revenue.
The High Court dismissed the appeal as withdrawn, granting the revenue the liberty to file an application for revival of the appeal as prayed for. The Court clarified that the withdrawal of the appeal by the revenue would not be considered an affirmation of the ITAT's order on merits. Furthermore, the legal issue claimed by the revenue was explicitly left open to be adjudicated in an appropriate case. No decision on the merits of the case was made.
The High Court dismissed the appeal as withdrawn, granting the revenue the liberty to file an application for revival of the appeal as prayed for. The Court clarified that the withdrawal of the appeal by the revenue would not be considered an affirmation of the ITAT's order on merits. Furthermore, the legal issue claimed by the revenue was explicitly left open to be adjudicated in an appropriate case. No decision on the merits of the case was made.
The High Court noted that similar issues had previously come before it in ITA-349-2017 (The Principal Commissioner of Income Tax-3, Ludhiana v. The Ludhiana Central Co-Op. Bank Ltd., Ludhiana) and other connected appeals involving the respondent-assessee. In those cases, the High Court, by order dated 24.9.2018, had dismissed the appeals filed by the revenue. Following its own precedent in the identical matter concerning the same assessee, the High Court dismissed the present appeal. The specific reasoning of the ITAT or the Supreme Court decision in State Bank of Travancore, or the implications of Section 43D or Section 145, were not elaborated upon by the High Court in this judgment as it relied on its prior decision.
The High Court held that no substantial question of law arises from the ITAT's order. The Tribunal had taken into consideration that the assessee-society had already been granted registration under Section 12AA of the Act, and its activities were found to be charitable by the Commissioner of Income Tax, Faridabad. The ITAT noted that the CIT(E) had not raised any question regarding the genuineness of the assessee-society's activities and that the sale of artwork was incidental to the main activity of providing training in art and painting to underprivileged children. The Tribunal found that the CIT(E) had not given valid reasons for rejecting the application, particularly regarding the anonymity of donations, as the assessee had submitted a list of donors with addresses. While acknowledging that 12AA registration alone does not entitle an assessee to 80G approval, the Court found that in the absence of any dispute regarding the aims and objects of the society, the denial of 80G approval could not be sustained. The revenue failed to demonstrate that the ITAT's view was erroneous or legally unsustainable. Consequently, the appeal was dismissed.
The High Court dismissed the appeal as withdrawn, granting liberty to the revenue to file an application for revival of the appeal as prayed for. The Court clarified that the withdrawal of the appeal by the revenue shall not be taken as an affirmation of the Tribunal's order on merits. Furthermore, the legal issue claimed by the revenue was left open to be adjudicated in an appropriate case. The ratio decidendi is that appeals can be withdrawn by the revenue based on monetary limits prescribed by CBDT circulars, without prejudice to the revenue's right to seek revival under specific circumstances, and without prejudice to the merits of the case for future adjudication.
The High Court dismissed the appeal as withdrawn. The court granted the revenue the liberty to file an application for revival of the appeal as prayed for. It was clarified that the withdrawal of the appeal by the revenue would not be considered an affirmation of the ITAT's order on merits. Furthermore, the legal issue, as claimed by the revenue, was left open to be adjudicated in an appropriate case. The court did not decide the merits of the case.
The High Court noted that the issue of exemption and maintenance of books of account had been a subject of remand in previous proceedings for subsequent assessment years. In those proceedings, the High Court had observed that the findings regarding the maintenance of books of account by the assessee were perverse and that the assessee had been unable to substantiate these findings. Consequently, the High Court had set aside the impugned orders and remanded the matter back to the Tribunal for a fresh decision. The Tribunal, in turn, had further remanded the matter to the AO, directing the assessee to produce books of accounts for verification. Given this procedural history and the ongoing nature of the verification of books of account by the primary authority (AO), the High Court decided to remit the matter back to the AO to decide the same afresh without going further into the issue. The appeal was disposed of accordingly.
The High Court held that no substantial question of law was involved and dismissed the appeal. The Court found that the assessee's contention that the authorities had not considered the figures of purchase and closing stock as per the VAT return deserved rejection. The judgment noted that the assessee filed an income tax return showing gross receipts of ` 9 lakhs, while cash deposits exceeded ` 37 lakhs. The assessee's attempt to explain the source of deposits by claiming actual sales of ` 29 lakhs was contradicted by the VAT return showing sales of ` 9,65,170/-. Furthermore, the assessee initially claimed not to maintain books of account, but filed a Trading and Profit & Loss Account and balance sheet with the VAT return, indicating withholding of material information. The Court observed that all three authorities below had recorded consistent findings of facts, which the appellant had not been able to dispute or prove as perverse. Therefore, no interference with the Tribunal's order was called for.
The High Court held that in view of CBDT Circular No. 3/2018, which stipulates that appeals with a tax effect below ₹50 lacs need not be pressed, the Revenue's submission to not press the appeal was accepted. Consequently, the instant appeal was dismissed as not pressed. The Court granted liberty to the Revenue to seek revival of the appeal if circumstances changed. The question of law was expressly kept open. The ratio decidendi is that appeals with low tax effect, as per CBDT circulars, can be withdrawn or not pressed, preserving the right to revive if necessary and keeping legal questions open.
The High Court held that in view of CBDT Circular No. 3/2018, which specifies a monetary limit for filing appeals, and considering the tax effect of ₹42,36,967 in this case, the appeal is dismissed as not pressed. The Court granted liberty to the Revenue to seek revival of the appeal if circumstances change. The question of law was also kept open. The operative direction is the dismissal of the appeal.
The High Court held that in view of CBDT Circular No. 3/2018, the instant appeal is dismissed as not pressed. The Revenue's counsel had stated that the tax effect was ₹13,28,800/-, which is below the ₹50 lacs threshold mentioned in the circular. Therefore, the Revenue did not want to press the appeal on merits. The Court granted liberty to the Revenue to seek revival of the appeal if circumstances change, as prayed for by the appellant's counsel. The question of law was also kept open. The operative direction was to dismiss the appeal as not pressed.
The High Court decided to dismiss the appeal as not pressed. The reasoning was based on the Revenue's submission that the tax effect involved was ₹2,59,075, which is below the threshold of ₹50 lacs stipulated in CBDT Circular No. 3/2018. Consequently, the Revenue did not want to pursue the appeal on its merits. The Court granted liberty to the Revenue to seek revival of the appeal if circumstances changed. The question of law was also expressly kept open. No specific finding was made on the merits of the original dispute.
The High Court of Punjab and Haryana at Chandigarh dismissed the appeal as not pressed. The Court noted the submission by the Revenue's counsel that the tax effect was ₹10,56,285/-, which was below the threshold stipulated in CBDT Circular No. 3/2018. Consequently, the Revenue did not want to pursue the appeal on its merits. The Court granted liberty to the Revenue to seek revival of the appeal if circumstances changed. The question of law was also kept open. No specific finding was reached on the merits of the original dispute.
The High Court held that in view of CBDT Circular No. 3/2018, the tax effect of ₹3,61,153/- being less than ₹50 lacs, the Revenue did not wish to press the appeal on merits. Consequently, the instant appeal was dismissed as not pressed. The Court, as prayed by the Revenue's counsel, granted liberty to the Revenue to seek revival of the appeal if circumstances changed. The question of law was also kept open. The ratio decidendi is that appeals with a tax effect below the threshold specified in CBDT circulars may be dismissed as not pressed, with liberty to seek revival.
The High Court held that in view of CBDT Circular No. 3/2018, which specifies that appeals with a tax effect of less than Rs. 50 lacs should not be pressed, and given that the tax effect in this case is Rs. 6,70,801/-, the appeal is dismissed as not pressed. The Court granted liberty to the Revenue to seek revival of the appeal if circumstances change. The question of law was expressly kept open. The reasoning is based solely on the administrative instruction provided by the CBDT Circular, not on the merits of the substantive tax dispute.
The High Court of Punjab and Haryana at Chandigarh dismissed the appeal as not pressed. The Revenue's counsel informed the court that the tax effect was ₹36,58,263/-, which is below the threshold of ₹50 lacs stipulated in CBDT Circular No. 3/2018. Consequently, the Revenue did not wish to press the appeal on its merits. The Court, in view of the CBDT Circular and the prayer made by the Revenue's counsel, dismissed the appeal. Liberty was granted to the Revenue to seek revival of the appeal if circumstances changed, and the question of law was expressly kept open.
The High Court held that in view of CBDT Circular No. 3/2018, the instant appeal is dismissed as not pressed. The Court granted liberty to the Revenue to seek revival of the appeal if circumstances changed. The question of law was also kept open. The reasoning is based on the Revenue's own submission that the tax effect was below the threshold stipulated in the circular, making it not worthwhile to pursue the appeal on merits. The operative direction is the dismissal of the appeal as not pressed, with liberty to seek revival and the question of law being kept open.
The High Court dismissed the appeal as withdrawn with liberty to the revenue to file an application for revival of the appeal as prayed for. The Court clarified that the withdrawal of the appeal by the revenue would not be considered an affirmation of the Income Tax Appellate Tribunal's order on merits. Furthermore, the legal issue, as claimed by the revenue, was left open to be adjudicated in an appropriate case. No specific finding was given on the merits of the case.
The High Court decided to dismiss the appeal as not pressed. The reasoning was based on the submission by the Revenue's counsel, who invoked CBDT Circular No. 3/2018. This circular provides guidelines on the monetary limits for filing appeals, and the tax effect in this case (₹4,51,447/-) fell below the specified threshold of ₹50 lacs. Consequently, the Revenue chose not to pursue the appeal on its merits. The Court granted the Revenue liberty to seek revival of the appeal if circumstances changed, and importantly, kept the question of law open for future consideration. No decision was made on the substantive merits of the ITAT's order.
The High Court held that in view of CBDT Circular No. 3/2018, which sets a monetary limit for appeals, and considering the tax effect of Rs. 3,98,352/- which is below Rs. 50 lacs, the appeal was dismissed as not pressed. The Court granted liberty to the Revenue to seek revival of the appeal if circumstances changed. The question of law was also kept open. The reasoning is based solely on the administrative instruction provided by the CBDT Circular, which guides the Revenue's decision to withdraw or not press appeals based on the tax effect. The ratio decidendi is that appeals with a tax effect below the threshold specified in relevant CBDT circulars may be dismissed as not pressed, with liberty to seek revival.
The Tribunal decided not to proceed with the appeal on its merits. Citing CBDT Circular No. 3/2018, which stipulates a monetary threshold for filing appeals, and noting that the tax effect in this case (Rs. 8,30,046/-) was below the Rs. 50 lacs limit, the Revenue stated it did not wish to press the appeal. Consequently, the Tribunal dismissed the appeal as not pressed. Liberty was granted to the Revenue to seek revival of the appeal if circumstances changed. The question of law was expressly kept open.
The High Court decided all substantial questions of law against the revenue and in favour of the assessee. Regarding questions 1-3 concerning copyright expenses, the Court referred to its prior decision in Principal Commissioner of Income Tax-2, Chandigarh vs. M/s Mobisoft Tele Solutions P. Limited (2018) 404 ITR 203. In that case, it was held that where only a license to use a copyright is granted and the copyright itself is not acquired, the license fee paid is a revenue expenditure. The Tribunal's finding that the assessee had only obtained a license was upheld. For question 4, concerning the second proviso to Section 40(a)(ia), the Court reiterated its decision in Pr. Commissioner of Income Tax-2, Chandigarh vs. Shivpal Singh Chaudhary (ITA No. 558 of 2017), agreeing with the Delhi High Court in CIT vs. Ansal Land Mark Township Private Limited (2015) 377 ITR 635. It was held that the second proviso to Section 40(a)(ia) and the first proviso to Section 201(1) are declaratory and curative, hence applicable retrospectively from 01.04.2005. The Tribunal's finding that the recipients of interest income had included it in their returns and paid taxes thereon, satisfying the conditions of the proviso, was also noted and upheld. Consequently, the appeal was dismissed.
The High Court of Punjab and Haryana at Chandigarh dismissed the appeal as not pressed. The Revenue's counsel stated that the tax effect was ₹1,41,725/-, which is below the threshold of ₹50 lacs stipulated in CBDT Circular No.3/2018. Consequently, the Revenue did not want to press the appeal on its merits. The Court accepted this submission and dismissed the appeal. Liberty was granted to the Revenue to seek revival of the appeal if circumstances changed. The question of law was also kept open.
The High Court held that in view of CBDT Circular No. 3/2018, which stipulates a monetary limit for appeals, and considering the tax effect of ₹22,96,875/- which is less than ₹50 lacs, the appeal was dismissed as not pressed. The Court granted liberty to the Revenue to seek revival of the appeal if circumstances changed. The question of law was expressly kept open. The reasoning was based on the Revenue's submission that they did not want to press the appeal on merits due to the tax effect being below the threshold specified in the circular. The ratio decidendi is that appeals with a tax effect below the prescribed limit in CBDT circulars may be dismissed as not pressed, with liberty to seek revival and the question of law remaining open.
The High Court held that in view of CBDT Circular No. 3/2018, which specifies a monetary limit for filing appeals, and the fact that the tax effect in this case (Rs. 16,155/-) is below the prescribed limit of Rs. 50 lacs, the Revenue did not wish to press the appeal on merits. Accordingly, the appeal was dismissed as not pressed. The Court granted liberty to the Revenue to seek revival of the appeal if circumstances changed. The question of law was expressly kept open.
The High Court decided not to press the appeal on merits. Citing CBDT Circular No. 3/2018, the Revenue stated that the tax effect of ₹42,51,810/- was below the threshold of ₹50 lacs, and therefore, they did not wish to pursue the appeal. The High Court, in view of this submission and the circular, dismissed the appeal as not pressed. Liberty was granted to the Revenue to seek revival of the appeal if circumstances changed. The question of law was also kept open.
The High Court dismissed the appeal as not pressed. The reasoning was based on the Revenue's submission that the tax effect of ₹34,08,125/- was below the monetary limit of ₹50 lacs as per CBDT Circular No. 3/2018. Consequently, the Revenue chose not to pursue the appeal on its merits. The Court granted liberty to the Revenue to seek revival of the appeal if circumstances changed. The question of law was expressly kept open. No specific relief was granted to the assessee on merits, nor was any deletion or remand ordered.
The High Court decided that the appeal should be dismissed as not pressed. The reasoning was based on the submission by the Revenue's counsel regarding the tax effect of ₹38,54,337/- and the applicability of CBDT Circular No. 3/2018. The circular sets a threshold of ₹50 lacs for filing appeals. Since the tax effect was below this threshold, the Revenue chose not to press the appeal on its merits. The Court granted liberty to the Revenue to seek revival of the appeal if circumstances changed. The question of law was also kept open.
The Tribunal decided to dismiss the appeal as not pressed. The reasoning was based on the Revenue's submission that the tax effect of ₹14,35,000/- was below the threshold stipulated in CBDT Circular No. 3/2018. This circular guides the Revenue on when to file appeals, and in this instance, the Revenue chose not to pursue the appeal on its merits due to the low tax effect. The Tribunal granted liberty to the Revenue to seek revival of the appeal if circumstances changed. The question of law was also kept open. The operative direction was the dismissal of the appeal.
The High Court held that in view of CBDT Circular No. 3/2018, the appeal is dismissed as not pressed. The court granted liberty to the Revenue to seek revival of the appeal if circumstances change. The question of law was also kept open. The reasoning is based on the Revenue's submission that the tax effect is below the threshold stipulated in the circular, making it not worthwhile to pursue the appeal on merits. The operative direction is the dismissal of the appeal. No issue was expressly left undecided, as the appeal was disposed of on a procedural ground.
The Tribunal decided to dismiss the appeal as not pressed. The reasoning was based on the Revenue's submission that the tax effect was below the threshold stipulated in CBDT Circular No. 3/2018, which advised against pursuing appeals with a low tax effect. The ratio decidendi is that appeals with a tax effect below the prescribed limit, as per CBDT circulars, may be withdrawn or not pressed by the Revenue. The operative direction was to dismiss the appeal. Liberty was granted to the Revenue to seek revival of the appeal if circumstances changed, and the question of law was kept open.
The Tribunal decided to dismiss the appeal as not pressed. The reasoning provided is based on the submission by the learned counsel for the Revenue that the tax effect involved in the case is ₹3,03,120/-, which is less than ₹50 lacs. This amount falls within the monetary limit specified in Circular No. 3/2018 issued by the Ministry of Finance, Department of Revenue, Central Board of Direct Taxes. Consequently, the Revenue stated it did not want to press the appeal on merits. The Tribunal, in view of the CBDT Circular and the Revenue's submission, dismissed the appeal. Liberty was granted to the Revenue to seek revival of the appeal if circumstances changed, and the question of law was kept open.
The High Court held that in view of CBDT Circular No.3/2018 dated 11.07.2018, which stipulates a monetary limit for pursuing appeals, and the tax effect in the present case being Rs.3,98,332/- (which is less than Rs.50 lacs), the Revenue did not want to press the appeal on merits. Consequently, the Court dismissed the appeal as not pressed. Liberty was granted to the Revenue to seek revival of the appeal if circumstances changed. The question of law was also kept open.
The High Court held that in view of CBDT Circular No. 3/2018, the appeal is dismissed as not pressed. The Revenue's counsel explicitly stated that they did not want to press the appeal on merits due to the tax effect being below the threshold mentioned in the circular. The Court granted liberty to the Revenue to seek revival of the appeal if circumstances change. The question of law was also kept open. The operative direction was the dismissal of the appeal as not pressed.
The High Court held that in view of the CBDT Circular No. 3/2018, the instant appeal is dismissed as not pressed. The Court granted liberty to the Revenue to seek revival of the appeal if circumstances changed, as prayed for by the counsel for the appellant. The question of law was also kept open. The reasoning was based solely on the Revenue's submission regarding the tax effect and the applicability of the CBDT circular, leading to the dismissal of the appeal without a decision on the merits of the substantive issues.
The High Court of Punjab and Haryana at Chandigarh, in view of the submission made by the learned counsel for the Revenue regarding the tax effect being ₹2,02,820/- and in light of CBDT Circular No. 3/2018, decided to dismiss the appeal as not pressed. The Court granted liberty to the Revenue to seek revival of the appeal if circumstances changed. The question of law was also expressly kept open. The reasoning is based on the administrative instruction provided by the CBDT to avoid litigation where the tax effect is below a certain threshold. The ratio decidendi is that appeals with a tax effect below the prescribed limit in the relevant CBDT circular can be dismissed as not pressed, without prejudice to the Revenue's right to revive the appeal later.