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601 orders · Page 5 of 13
The High Court allowed the prayer for withdrawal of the appeal. The Court noted that Circular No. 5/2024, effective from September 17, 2024, has revised the monetary limits for filing appeals before various authorities, including the High Court. The court observed that the present case did not fall within the exceptions provided in the circular. Consequently, the appeal was dismissed as withdrawn. The reasoning is based on the assessee's counsel's submission and the court's acceptance of the prayer for withdrawal in light of the revised monetary limits and the purpose of managing litigation. The ratio decidendi is that appeals can be withdrawn if they no longer meet the revised monetary thresholds stipulated by the government for litigation management, unless they fall under specific exceptions.
The High Court allowed the prayer for withdrawal of the appeal. The appeal was accordingly dismissed as withdrawn in light of the revised monetary limits specified in the CBDT Circular.
The High Court held that notices issued under Section 148 of the Income Tax Act, 1961, and the consequential proceedings initiated without conducting the faceless assessment as envisaged under Section 144B, are contrary to the provisions of the Act and are therefore without jurisdiction. The Court reiterated its previous decision in Jasjit Singh vs. Union of India, stating that circulars or instructions issued by the Board cannot override statutory provisions or make them obsolete. Legislative enactments with financial implications must be followed strictly. The Court found that the authorities cannot usurp legal provisions to their own satisfaction or convenience, causing hardship and confusion to assessees. Therefore, the notices dated 23.03.2023, 20.03.2024, 16.03.2023, 30.03.2023, and the order dated 30.03.2023 were set aside for want of jurisdiction. The revenue was granted liberty to follow the procedure laid down under the Act and proceed accordingly, if so advised. The writ petition was allowed, and interim orders were merged with the final order.
The High Court held that the petitioner is entitled to the same relief as granted in the case of Jyoti Sareen vs. Union of India and others. Consequently, the impugned notice dated March 28, 2024, issued to the petitioner under Section 148 of the Income Tax Act, 1961, along with any consequential proceedings, was quashed. The court allowed the petition in terms of the Jyoti Sareen judgment. No specific amount in dispute was recorded. Any pending miscellaneous applications were also disposed of.
The High Court allowed the prayer for withdrawal of the appeal. The Court noted that the appellant's counsel submitted that in terms of Circular No. 5/2024, the monetary limits for filing appeals have been enhanced. The counsel further prayed for the withdrawal of the present appeal, stating that the case does not fall within the exception clause of Circular No. 5/2024. The Court found this submission acceptable and accordingly, allowed the prayer. The appeal was dismissed as withdrawn. The reasoning is primarily based on the administrative decision to manage litigation by revising monetary limits for appeals, and the appellant's counsel's submission that the present case falls within the scope of withdrawal under the new circular. The operative direction was to dismiss the appeal as withdrawn. No specific issue was left undecided, as the appeal was disposed of on a procedural ground.
The High Court allowed the prayer for withdrawal of the appeal. The Court noted that Circular No. 5/2024, effective from 17.09.2024, has enhanced the monetary limits for filing appeals before the ITAT, High Court, and Supreme Court. The Court observed that the present case does not fall within the exception clauses of the circular, which allow for appeals to be decided on merits irrespective of tax effect. Consequently, the Court directed that the appeal be dismissed as withdrawn. All pending miscellaneous applications were also disposed of. The principle established is that appeals that do not meet the revised monetary thresholds, and do not fall under any exceptions, are to be withdrawn and dismissed.
The High Court held that notices issued under Section 148 of the Income Tax Act, 1961, and the subsequent faceless assessment proceedings initiated without conducting the assessment as envisaged under Section 144B, were found to be contrary to the provisions of the Act, 1961. The Court relied on its previous decisions in Jasjit Singh vs. Union of India and Jatinder Singh Bhangu vs. Union of India. In these prior judgments, the Court had held that circulars or instructions from the Board could not override statutory provisions or make them obsolete. Legislative enactments with financial implications must be followed mandatorily. The Court reasoned that authorities cannot usurp legal provisions for their own satisfaction or convenience, causing hardship and confusion to assessees. Therefore, the notice dated 08.04.2022 and all consequential proceedings were set aside for want of jurisdiction. The revenue was granted liberty to follow the procedure laid down under the Act, 1961, and proceed accordingly if advised. All pending applications were also disposed of.
The High Court held that notices issued under Section 148 of the Income Tax Act, 1961, and subsequent faceless assessment proceedings initiated without conducting the assessment as envisaged by Section 144B of the Act, were found to be contrary to the provisions of the Act. The Court agreed with the view taken by coordinate benches, stating that administrative instructions or circulars cannot override statutory provisions or be issued to make them otiose. The Court emphasized that legislative enactments with financial implications must be followed mandatorily. Exercising powers under Sections 119 and 120 of the Act, authorities cannot usurp legal provisions for their convenience, causing hardship and confusion. Instructions can only supplement statutory provisions and aid in their implementation. Consequently, the notices dated 10.04.2023 (Annexure P-6), and other consequential proceedings were set aside for want of jurisdiction. The revenue was granted liberty to follow the procedure laid down under the Act if so advised. The writ petition was allowed.
The High Court held that notices issued under Section 148 of the Income Tax Act, 1961, and the subsequent proceedings initiated under the faceless assessment scheme, without conducting the assessment as envisaged by Section 144B (7 & 8) of the Act, were found to be contrary to the provisions of the Act. The court relied on its previous decisions in Jasjit Singh vs. Union of India and Jatinder Singh Bhangu vs. Union of India. The reasoning was that instructions by the Board, even if issued under Sections 119 and 120 of the Act, could not override statutory provisions or make them otiose. Authorities cannot usurp legal provisions for their convenience, causing hardship and confusion to assessees. Circulars and instructions should supplement statutory provisions and aid implementation. Therefore, the notice dated 31.03.2024 and all consequential proceedings were set aside for want of jurisdiction. The revenue was granted liberty to follow the procedure laid down under the Act, if so advised. The writ petition was allowed, and interim orders stood merged with the final order.
The High Court allowed the writ petition. It held that circulars or instructions issued by the Board cannot override statutory provisions or render them obsolete. Legislative enactments with financial implications must be strictly followed. The court found that by exercising powers under Sections 119 and 120 of the Act, 1961, as well as Section 144B(7 & 8), authorities cannot usurp legal provisions for their convenience, causing hardship to assessees and confusion. Instructions and circulars can only supplement statutory provisions and aid in their implementation. Consequently, notices issued by the JAO under Section 148 and proceedings initiated thereafter without conducting faceless assessment as envisaged under Section 144B were found to be contrary to the Act, 1961. The specific notice dated 27.03.2024 and consequential proceedings were set aside for want of jurisdiction. The revenue was granted liberty to follow the procedure laid down under the Act, 1961, if advised. The operative direction was to set aside the notice and consequential proceedings.
The High Court allowed the writ petition, setting aside the notice dated March 27, 2024, issued by the Jurisdictional Assessing Officer under Section 148 of the Income Tax Act, 1961, and the consequential proceedings. The Court reiterated its agreement with the view taken by a Coordinate Bench in Jasjit Singh vs. Union of India and others. The Tribunal held that circulars or instructions issued by the Board cannot override statutory provisions or render them otiose. Legislative enactments with financial implications must be followed strictly and mandatorily. The Court found that authorities, by exercising powers under Sections 119 and 120, and Section 144B (7 & 8) of the Act, cannot usurp legal provisions for their satisfaction and convenience, causing hardship. Instructions and circulars can only supplement statutory provisions and aid in their implementation. Therefore, notices issued under Section 148 and proceedings initiated without conducting faceless assessments under Section 144B were found to be contrary to the Act and set aside for want of jurisdiction. The revenue was granted liberty to follow the prescribed procedure if advised. The operative direction was to set aside the notice and consequential proceedings.
The High Court held that circulars or instructions issued by the Board cannot override statutory provisions or render them obsolete. Legislative enactments with financial implications must be strictly followed. Authorities cannot usurp legal provisions for their convenience, causing hardship to assessees, nor should they create confusion for taxpayers. Instructions and circulars can only supplement statutory provisions and aid in their implementation. Consequently, notices issued by the JAO under Section 148 of the Act and subsequent proceedings initiated without conducting faceless assessment as envisaged under Section 144B of the Act were found to be contrary to the Act and set aside for want of jurisdiction. The Court allowed the writ petition, setting aside the notice dated 31.08.2024 and consequential proceedings. The revenue was granted liberty to follow the prescribed procedure if advised. The ratio is that faceless assessment is a mandatory procedural requirement, and non-compliance vitiates the assessment proceedings.
The High Court allowed the withdrawal of the appeal. The court noted that the case did not fall within any exceptions to the revised monetary limits specified in the circular.
The High Court allowed the petitioner's request to withdraw the writ petition. The court granted liberty to the petitioner to file a fresh petition on the same cause of action. Furthermore, the court permitted the petitioner to challenge Section 147A of the Income Tax Act, 1961, in the fresh petition. The petition was dismissed as withdrawn with the liberty as prayed for. No specific findings were made on the merits of the challenge to Section 147A, as the petition was withdrawn before any substantive adjudication.
The High Court allowed the Revenue's prayer to withdraw the appeal. Consequently, the appeal was dismissed as withdrawn, and any pending applications were also disposed of.
The Tribunal allowed the prayer for withdrawal of the appeal. The reasoning was based on the issuance of Circular No. 9/2024 dated 17.09.2024, which revised the monetary limits for filing appeals in income-tax cases. The circular stipulated that appeals/SLPs before the Supreme Court should have a tax effect of ₹5 crore, before the High Court ₹2 crore, and before the ITAT ₹60 lakh. The circular also stated that these limits, with exceptions, would apply to all cases, including those relating to TDS/TCS, and would be effective from the date of issuance. The Revenue contended that the present appeal did not fall within the exceptions to Circular No. 5/2024. Consequently, the Revenue sought to withdraw the appeal. The Tribunal accepted this submission and allowed the withdrawal. All pending applications were also disposed of accordingly.
The High Court allowed the Revenue's prayer for withdrawal of the appeal. Consequently, the appeal was dismissed based on the revised monetary limits for litigation management.
The Tribunal allowed the Revenue's prayer for withdrawal of the appeal. The appeal was dismissed as withdrawn based on the revised monetary limits stipulated in the circular.
The High Court held that the appeal No. ITA-15-2022 does not fall within the exception clause of Circular No. 5/2024. Consequently, the learned counsel for the appellant prayed for the withdrawal of the appeal. The Court allowed this prayer and dismissed the appeal as withdrawn. The reasoning is based on the applicability of the enhanced monetary limits introduced by Circular No. 9/2024, which revised the limits for filing appeals in income-tax cases. The Court found that the present appeal, based on the information presented and the circulars cited, did not meet the criteria for an exception. Therefore, the appeal was permitted to be withdrawn. All pending applications were also disposed of accordingly. The Court did not decide on the merits of the case.
The High Court allowed the Revenue's prayer for withdrawal of the appeal. The Court noted that Circular No. 9/2024 dated 17.09.2024, issued by the Ministry of Finance, Department of Revenue, had revised the monetary limits for filing appeals in income-tax matters before the Income Tax Appellate Tribunal (Rs. 60 lakh), High Court (Rs. 2 crore), and Supreme Court (Rs. 5 crore). The circular stipulated that these revised limits would apply to all appeals/SLPs, including those relating to TDS/TCS, irrespective of the tax effect, unless the decision was on merits and fell under specific exceptions mentioned in Circular No. 5/2024. Since the present appeal (ITA-103-2022) did not fall within the exceptions of Circular No. 5/2024, the Revenue was permitted to withdraw it. All pending applications were also disposed of accordingly. The operative direction was to dismiss the appeal as withdrawn.
The Tribunal allowed the withdrawal of the appeal. The Revenue's counsel submitted that Circular No. 9/2024, issued by the Ministry of Finance, Department of Revenue, has enhanced the monetary limits for filing appeals before the ITAT, High Court, and Supreme Court. The revised limits are Rs. 60 lakh for ITAT, Rs. 2 crore for High Court, and Rs. 5 crore for Supreme Court. The Revenue argued that the present appeal did not fall within the exceptions to these limits as per Circular No. 5/2024. Consequently, the Revenue prayed for the withdrawal of the appeal. The Tribunal, accepting the submission, allowed the prayer and dismissed the appeal as withdrawn. All pending applications were also disposed of accordingly.
The Tribunal allowed the Revenue's prayer to withdraw the appeal. It held that the appeal was to be dismissed in light of the revised monetary limits for filing appeals as per the circular.
The High Court allowed the Revenue's prayer for withdrawal of the appeal. Consequently, the appeal was dismissed as withdrawn, and pending applications were also disposed of.
The Tribunal held that the Income Tax Appeal (ITA) is dismissed for non-prosecution. The reasoning is based on the fact that the parties were repeatedly informed by the Registry to take steps for the reconstruction of the file, but no such steps were taken. Furthermore, the file itself was stated to have been fully burnt in a fire incident that occurred in the Registry. In view of these circumstances, the appeal could not be prosecuted. The Tribunal also noted that all pending miscellaneous applications stood disposed of. No specific issue was left undecided; the appeal was dismissed on procedural grounds.
The High Court allowed the prayer for withdrawal of the appeal. The Court noted that the monetary limits for filing appeals by the department before the ITAT, High Court, and Supreme Court have been enhanced by Circular No. 9/2024 dated 17.09.2024. The court observed that these modifications came into effect from the date of issuance of the circular and apply to appeals to be filed before the High Court. Since the present appeal was stated to not fall within the exception clause of Circular No. 5/2024, the court permitted the withdrawal of the appeal. The operative direction was to allow the prayer for withdrawal, and consequently, the appeal was dismissed as withdrawn. All pending applications were also disposed of.
The Tribunal allowed the prayer for withdrawal of the appeal. The Revenue submitted that in view of the enhanced monetary limits for filing appeals, as per Circular No. 9/2024 dated 17.09.2024, the present appeal did not meet the revised threshold. The Revenue specifically stated that the case did not fall within the exception clause of Circular No. 5/2024. Consequently, the learned counsel for the Revenue prayed for the withdrawal of the present appeal. The Tribunal, acceding to this request, allowed the prayer and dismissed the appeal. All pending applications were also disposed of accordingly. The ratio decidendi is that appeals filed by the Revenue, which no longer meet the revised monetary limits prescribed by CBDT circulars, can be withdrawn by the Revenue.
The Tribunal allowed the prayer for withdrawal of the appeal. The reasoning was based on the submission by the Revenue's counsel regarding the revised monetary limits for filing appeals as per CBDT Circular No. 5/2024, as amended by Circular No. 9/2024. The Revenue stated that the present appeal did not fall within any exception to these revised limits. The Tribunal found that the appeal was to be withdrawn in view of the aforementioned circulars. Accordingly, the appeal was dismissed as withdrawn. No issue was expressly left undecided; the entire appeal was disposed of based on the withdrawal.
The Tribunal allowed the Revenue's prayer for withdrawal of the appeal. The decision was based on the revised monetary limits for filing appeals as stipulated in Circular No. 9/2024 dated 17.09.2024 and Circular No. 5/2024 dated 15.03.2024. The Revenue's counsel submitted that these circulars were issued to manage litigation and that the present appeal did not fall within the exceptions provided in Circular No. 5/2024. The Tribunal found merit in the prayer for withdrawal. Consequently, the appeal was dismissed as withdrawn. All pending applications were also disposed of accordingly. The judgment does not record any decision on the merits of the original dispute.
The High Court allowed the prayer for withdrawal of the appeal. The Court noted that Circular No. 9/2024 dated 17.09.2024, issued by the Ministry of Finance, Department of Revenue, had enhanced the monetary limits for filing appeals by the department before the Income Tax Appellate Tribunal, High Court, and Supreme Court. The Court was informed that the present appeal, ITA-354-2016, did not fall within any exceptions to Circular No. 5/2024. Consequently, the Revenue's counsel prayed for the withdrawal of the appeal. The Court found merit in this submission and allowed the prayer. All pending applications were also disposed of accordingly. The operative direction was to dismiss the appeal as withdrawn.
The Tribunal allowed the Revenue's prayer for withdrawal of the appeal. The reasoning was based on the issuance of Circular No. 9/2024 dated 17.09.2024, which revised the monetary limits for filing appeals by the department. The circular stipulated that appeals/SLPs with a tax effect below certain enhanced limits would not be filed, and those pending would be withdrawn, unless they fall under specific exceptions. The Revenue contended that the present appeal did not meet the criteria for continuation under the new circular and specifically did not fall within the exceptions of Circular No. 5/2024. Consequently, the Tribunal found no impediment to allowing the withdrawal. The operative direction was to permit the withdrawal of the appeal. Any pending applications were also disposed of accordingly. The judgment did not expressly leave any issue undecided.
The Tribunal allowed the prayer for withdrawal of the appeal. The reasoning was based on the issuance of Circular No. 9/2024 dated 17.09.2024, which revised the monetary limits for filing appeals before the Income Tax Tribunal, High Courts, and the Supreme Court. The circular stipulated that appeals would be filed based on enhanced tax effect thresholds. The Revenue's counsel stated that the present appeal did not fall within any exception clause of Circular No. 5/2024. Consequently, the Tribunal found no impediment to allowing the withdrawal. The operative direction was to dismiss the appeal as withdrawn. All pending applications were also disposed of accordingly.
The High Court allowed the application for withdrawal of the appeal. The Court noted that Circular No. 9/2024 dated 17.09.2024, issued by the CBDT, revises the monetary limits for filing appeals. The Revenue submitted that the present case does not fall within any exception clause of Circular No. 5/2024, which deals with exceptions to the monetary limits. Based on this submission and the revised monetary limits, the Revenue prayed for the withdrawal of the appeal. The Court found merit in the prayer and accordingly allowed the application. Consequently, the appeal filed by the Revenue was dismissed as withdrawn. All pending applications were also disposed of accordingly. The Court did not decide the substantive merits of the appeal.
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 Court explicitly stated that the legal issue, as claimed by the revenue, was being 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 Tribunal allowed the application for dismissal of the appeal. The reasoning was based on the application of CBDT Circular No. 9/2024 dated 17.09.2024. The Tribunal noted that the Revenue had submitted that the case did not fall within any exception clause of Circular No. 5/2024, which was referenced by Circular No. 9/2024. Consequently, the Revenue prayed for the withdrawal of the appeal. The Tribunal accepted this prayer and allowed the application. The appeal was accordingly dismissed as withdrawn. The operative direction was to dismiss the appeal. Any pending applications were also disposed of accordingly.
The Tribunal allowed the Revenue's prayer for withdrawal of the appeal. The Tribunal noted that the Revenue's counsel submitted that the case does not fall within any exception to the revised monetary limits stipulated in Circular No. 9/2024, which amends Circular No. 5/2024. Consequently, the Tribunal allowed the applications for withdrawal and dismissed the appeal as withdrawn. The operative direction was to dismiss the appeal. No issues were expressly left undecided, as the appeal was withdrawn before any decision on merits.
The Tribunal allowed the prayer for withdrawal of the appeal. The reasoning was based on the provisions of Circular No. 9/2024 dated 17.09.2024, which revised the monetary limits for filing appeals. The Tribunal noted that the modifications came into effect from 17.09.2024 and are applicable to appeals to be filed as well as pending appeals. The Tribunal found that the present case did not fall within the exception clause of Circular No. 5/2024. Therefore, the Revenue was permitted to withdraw the appeal. The operative direction was to allow the withdrawal and dismiss the appeal as withdrawn. No issue was expressly left undecided.
The Tribunal allowed the Revenue's prayer for withdrawal of the appeal. The appeal was dismissed in light of the revised monetary limits for litigation as per the new government circular.
The High Court held that the reason provided by the appellant for non-appearance before the ITAT on 18.07.2023, i.e., heavy rains and a yellow alert, appeared to be a valid reason. The Court found that the ITAT ought to have considered this aspect but failed to do so, proceeding ex-parte. Consequently, the High Court set aside the ITAT's order dated 07.08.2023. The Court directed the ITAT to decide the appeal afresh after giving a fair hearing to both parties. The appellant was instructed to present themselves before the ITAT on 20.11.2024, and no further adjournment would be granted. The appellant was also permitted to file all necessary documents and submissions before the concerned date. The appeal was allowed in these terms.
The Tribunal allowed the withdrawal of the appeal. The Revenue's counsel informed the Court about Circular No. 9/2024 dated 17.09.2024, which revised the monetary limits for filing appeals before the Income Tax Appellate Tribunal (Rs. 60 lakh), High Court (Rs. 2 crore), and Supreme Court (Rs. 5 crore). This circular applies to all cases, including those relating to TDS/TCS, with exceptions as per paras 3.1 and 3.2 of Circular No. 5/2024. The Revenue argued that the present appeal does not fall within these exceptions and therefore, it should be withdrawn. The Tribunal found merit in the submission and allowed the prayer for withdrawal. Consequently, the appeal was dismissed as withdrawn. All pending applications were also disposed of accordingly.
The tribunal allowed the Revenue's prayer for withdrawal of the appeal. Consequently, the appeal was dismissed as withdrawn based on the revised monetary limits for litigation.
The Tribunal allowed the Revenue's prayer for withdrawal of the appeal. Consequently, the appeal was dismissed as withdrawn, aligning with the revised monetary limits for litigation.
The Tribunal allowed the department's prayer to withdraw the appeal. Consequently, the appeal was dismissed as withdrawn.
The tribunal allowed the withdrawal of the appeal. The court noted that the revised circular aimed to manage litigation and that the present case did not meet any exceptions to the new monetary limits.
The Tribunal allowed the prayer for withdrawal of the appeal. The reasoning was based on the applicability of CBDT Circular No. 9/2024 dated September 17, 2024, which revised the monetary limits for filing appeals. The appellant's counsel submitted that the present case did not fall within the exceptions to these revised limits. Consequently, the Revenue sought to withdraw the appeal. The Tribunal, in view of the circular and the submissions made, allowed the prayer and accordingly, the appeal was dismissed as withdrawn. All pending applications were also dismissed as withdrawn. No specific finding was made on the merits of the original appeal, as it was withdrawn.
The Tribunal allowed the appellant's prayer for withdrawal of the appeal. The reasoning was based on the submission that the revised monetary limits for filing appeals by the department, as per Circular No. 9/2024 dated 17.09.2024, were applicable. The appellant's counsel argued that their case did not fall within the exceptions to these revised limits. Consequently, the Tribunal found no impediment to allowing the withdrawal. The operative direction was to dismiss the appeal as withdrawn. Any pending applications were also dismissed accordingly. The judgment does not discuss the merits of the original appeal or the tax effect in detail, as the appeal was disposed of on procedural grounds of withdrawal.
The Tribunal allowed the Revenue's prayer for withdrawal of the appeal. The reasoning was based on the applicability of CBDT Circular No. 9/2024 dated 17.09.2024, which revised the monetary limits for filing appeals. The Tribunal noted that the Revenue had submitted that the present case did not fall within the exceptions to the Circular. Consequently, the Tribunal permitted the withdrawal of the appeal. The operative direction was that the appeal is dismissed as withdrawn. All pending applications were also dismissed as withdrawn. The Tribunal did not decide the merits of the case.
The High Court allowed the prayer of the assessee to withdraw the appeal. The court noted that the revised monetary limits for filing appeals, as per Circular No. 9/2024 dated 17.09.2024, are applicable to all cases, including those pending before the Supreme Court, High Court, and Tribunal. The court also acknowledged that the present case did not fall within the exceptions to these monetary limits as per Circular No. 5/2024. Consequently, the appeal was dismissed as withdrawn. All pending applications were also disposed of accordingly.
The Tribunal allowed the prayer of the Revenue to withdraw the present appeal. The reasoning was based on the application of CBDT Circular No. 9/2024 dated September 17, 2024. The circular revised the monetary limits for filing appeals before the Income Tax Tribunal, High Courts, and the Supreme Court. The Tribunal noted that the modifications came into effect from the date of issuance of the circular and therefore apply to all appeals pending before the Supreme Court, High Court, and Tribunal. Since the present case did not fall within the exceptions to the monetary limits as per Circular No. 5/2024, the Revenue's request for withdrawal was acceded to. The appeal was accordingly dismissed as withdrawn. The Tribunal also directed that all pending applications stand dismissed as withdrawn.
The Tribunal allowed the prayer for withdrawal of the present appeal. The reasoning was based on the application of CBDT Circular No. 9/2024 dated September 17, 2024, which revises the monetary limits for filing appeals. The Circular states that the decision to appeal or file an SLP shall be taken on merits, without regard to the tax effect, except for specific exceptions. However, the present case, as submitted by the counsel, does not fall within these exceptions. The Tribunal noted that the modifications in the Circular came into effect from the date of issuance and apply to appeals pending before the Supreme Court, High Court, and Tribunal. Consequently, the appeal was dismissed as withdrawn. All pending applications were also disposed of accordingly.