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The High Court held that the Income Tax Reference Application should be dismissed as not pressed. The Court took note of CBDT Circular No. 21/2015, which sets a monetary limit of Rs. 20,00,000/- for filing appeals before the High Court. Since the tax effect in the present case was indisputably less than Rs. 20 lac, the application was deemed to be covered by the circular's provisions for withdrawing or not pressing pending appeals below the specified limits. The Court clarified that any substantial questions of law raised in the reference application were left open to be examined in an appropriate future proceeding. The Revenue was also granted liberty to move an application for recalling the order if the reference application fell under any of the exceptions mentioned in the circular.
