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495 orders · Page 9 of 10
The High Court held that the appeals filed by the Revenue, with a tax effect indisputably less than Rs. 20 lac (which is the prescribed limit for filing appeals before the High Courts as per CBDT Circular No. 21/2015), deserve to be dismissed as not pressed. The Court noted that the Circular applies retrospectively to pending appeals. However, it clarified that the substantial questions of law raised in the appeals are left open to be examined in appropriate future proceedings. The Revenue was granted liberty to move an application for recalling the order if the appeal falls under any of the exceptions mentioned in the Circular dated 10.12.2015, such as challenges to constitutional validity or adverse judgments on Board's orders, instructions, or circulars, or where the addition relates to undisclosed foreign assets/bank accounts.
The High Court held that the appeals filed by the Revenue were to be dismissed as not pressed, taking note of CBDT Circular dated 10.12.2015 and the fact that the tax effect in the instant cases was less than Rs. 20 lac, which is the prescribed limit for filing appeals before the High Courts. The Court clarified that the substantial questions of law raised in the appeals, if any, were left open to be examined in appropriate future proceedings. Furthermore, the Revenue was granted liberty to move an application for recalling the order if the appeal fell under any of the exceptions mentioned in the Circular dated 10.12.2015. The operative direction was to dismiss the appeals as not pressed.
The High Court held that the appeals, having a tax effect less than Rs. 20 lac, were to be dismissed as not pressed, in view of CBDT Circular No. 21/2015 dated 10.12.2015. The circular, which applies retrospectively to pending appeals, sets a monetary limit of Rs. 20,00,000/- for filing appeals before the High Court. The Court clarified that substantial questions of law raised in these appeals are left open for examination in future proceedings. It also granted liberty to the Revenue to move an application for recalling the order if any of the appeals fall under the exceptions mentioned in paragraph 8 of the circular. The ratio is that appeals with a tax effect below the prescribed monetary limit in the CBDT circular should be withdrawn or not pressed, unless they fall under specific exceptions.
The High Court held that the appeals filed by the Revenue, with a tax effect indisputably less than Rs. 20 lac (and thus less than the prescribed limit for High Court appeals), deserved to be dismissed as not pressed, in light of CBDT Circular No. 21/2015. The Court noted that the circular applies retrospectively to pending appeals. However, the Court clarified that the substantial questions of law raised in the appeals, if any, were left open to be examined in appropriate future proceedings. The Revenue was also granted liberty to move an application for recalling the order if the appeal fell under any of the exceptions mentioned in paragraph 8 of the circular. The operative direction was to dismiss the appeals as not pressed.
The High Court held that the instant appeals, with a tax effect indisputably less than Rs. 20 lac (which is the prescribed monetary limit for filing appeals before the High Courts as per CBDT Circular No. 21/2015), deserve to be dismissed as not pressed. The Court noted that the circular applies retrospectively to pending appeals. However, it clarified that the substantial questions of law raised in the appeals, if any, are left open to be examined in appropriate future proceedings. The Court also observed that if any appeal falls under the exceptions mentioned in the circular (para 8), the Revenue would be at liberty to move an application for recalling the order. Accordingly, the appeals were dismissed as not pressed in light of the CBDT Circular dated 10.12.2015.
The Tribunal held that the instant appeals, with a tax effect indisputably less than Rs. 20 lac (which is less than the prescribed limit for filing appeals before the High Courts), deserved to be dismissed as not pressed in light of CBDT Circular No. 21/2015. The Tribunal clarified that the substantial questions of law raised in the appeals, if any, were left open to be examined in future appropriate proceedings. It was also observed that if any appeal fell within the exceptions mentioned in the circular, the Revenue would be at liberty to move an application for recalling the order. Consequently, the appeals were dismissed as not pressed.
The High Court held that the appeals deserved to be dismissed as not pressed, taking note of CBDT Circular No. 21/2015 and the fact that the tax effect in the instant case was less than Rs. 20 lac, which is the prescribed limit for filing appeals before the High Courts. The Court clarified that the substantial questions of law raised in the appeals, if any, were left open to be examined in an appropriate proceeding in the future. The Court also observed that if any appeal fell within the exceptions referred to in the Circular, the Revenue would be at liberty to move an application for recalling the order. Accordingly, the appeals were dismissed as not pressed in light of the CBDT Circular dated 10.12.2015.
The Tribunal held that the appeals, with a tax effect indisputably less than Rs. 20 lac (which is the prescribed limit for filing appeals before the High Courts as per CBDT Circular No. 21/2015), deserve to be dismissed as not pressed. The Tribunal noted that the Circular applies retrospectively to pending appeals. It was clarified that the substantial questions of law raised in the appeals, if any, are left open to be examined in future appropriate proceedings. The Revenue was granted liberty to move an application for recalling the order if any of the appeals fall under the exceptions mentioned in paragraph 8 of the Circular dated 10.12.2015. Consequently, the appeals were dismissed as not pressed in light of the CBDT Circular.
The High Court held that the appeals filed by the Revenue deserved to be dismissed as not pressed, taking note of CBDT Circular No. 21/2015 and the fact that the tax effect in the instant case was less than Rs. 20,00,000/-, which is the prescribed limit for filing appeals before the High Courts. The Court clarified that the substantial questions of law raised in the appeals, if any, were left open to be examined in future appropriate proceedings. The Court also observed that if the appeal fell under any of the exceptions mentioned in the Circular dated 10.12.2015, the Revenue would be at liberty to move an application for recalling the order. Accordingly, the appeals were dismissed as not pressed.
The Tribunal held that the appeals, with a tax effect indisputably less than Rs. 20 lac (which is the prescribed limit for filing appeals before the High Courts as per CBDT Circular No. 21/2015), deserve to be dismissed as not pressed. The Tribunal noted that the Circular applies retrospectively to pending appeals. It was clarified that the substantial questions of law raised in the appeals, if any, are left open to be examined in future appropriate proceedings. The Revenue was granted liberty to move an application for recalling the order if any of the appeals fall under the exceptions mentioned in paragraph 8 of the Circular dated 10.12.2015. Consequently, the appeals were dismissed as not pressed in light of the CBDT Circular.
The High Court held that the appeals deserved to be dismissed as not pressed, taking into account CBDT Circular No. 21/2015 and the fact that the tax effect in the instant cases was less than Rs. 20 lac, which is the prescribed limit for filing appeals before the High Courts. The Court clarified that the substantial questions of law raised in the appeals, if any, are left open to be examined in future appropriate proceedings. The Court also stated that if the appeal falls within any of the exceptions mentioned in the Circular dated 10.12.2015, the Revenue would be at liberty to move an application for recalling the order. Accordingly, the appeals were dismissed as not pressed.
The Tribunal held that the appeals, with a tax effect less than Rs. 20 lac, should be dismissed as not pressed in light of CBDT Circular No. 21/2015. The circular, which applies retrospectively to pending appeals, sets a monetary limit of Rs. 20 lac for filing appeals before the High Court. The Tribunal noted that while the circular provides exceptions for certain types of cases (e.g., constitutional validity challenges, adverse rulings on Board's orders, undisclosed foreign assets), the present appeals did not fall under these exceptions. The Tribunal clarified that the substantial questions of law raised in these appeals are left open for future examination if they arise in appropriate proceedings. The Revenue was granted liberty to move an application for recalling the order if the appeal fell under any of the exceptions mentioned in the circular. Accordingly, the appeals were dismissed as not pressed.
The Tribunal held that the appeals should be dismissed as not pressed, taking into account CBDT Circular No. 21/2015 and the fact that the tax effect in these appeals is less than Rs. 20 lakhs, which is the prescribed limit for filing appeals before the High Courts. The Tribunal clarified that the substantial questions of law raised in the appeals are left open to be examined in future appropriate proceedings. It also observed that if any appeal falls under the exceptions mentioned in the circular (e.g., constitutional validity, adverse rulings on Board's orders), the Revenue is at liberty to move an application for recalling the order. The ratio decidendi is that appeals with a tax effect below the prescribed monetary limits, as per the CBDT circular, should be dismissed as not pressed, unless specific exceptions apply.
The Tribunal held that the appeals should be dismissed as not pressed, taking into account CBDT Circular No. 21/2015 and the fact that the tax effect in these appeals is less than Rs. 20 lakhs, which is the prescribed limit for filing appeals before the High Courts. The Tribunal clarified that the substantial questions of law raised in the appeals are left open to be examined in future appropriate proceedings. It also observed that if any appeal falls under the exceptions mentioned in the circular (e.g., constitutional validity, adverse rulings on Board's orders), the Revenue is at liberty to move an application for recalling the order. The ratio decidendi is that appeals with a tax effect below the prescribed monetary limits, as per the CBDT circular, should be dismissed as not pressed, unless specific exceptions apply.
The Tribunal held that the appeals should be dismissed as not pressed, taking into account CBDT Circular No. 21/2015 and the fact that the tax effect in these appeals is less than Rs. 20 lakh, which is the prescribed limit for filing appeals before the High Court. The Tribunal clarified that the substantial questions of law raised in these appeals are left open to be examined in future appropriate proceedings. It also observed that if any appeal falls under the exceptions mentioned in the circular, the Revenue is at liberty to move an application for recalling the order. The operative direction is that the appeals stand dismissed as not pressed.
The High Court held that the appeals deserved to be dismissed as not pressed, taking into account CBDT Circular No. 21/2015 and the fact that the tax effect in the instant cases was less than Rs. 20 lac, which is the prescribed limit for filing appeals before the High Courts. The Court clarified that the substantial questions of law raised in the appeals, if any, are left open to be examined in future appropriate proceedings. The Court also stated that if the appeal falls within any of the exceptions mentioned in the Circular dated 10.12.2015, the Revenue would be at liberty to move an application for recalling the order. Accordingly, the appeals were dismissed as not pressed.
The Tribunal held that the appeals, with a tax effect indisputably less than Rs. 20 lac (which is the prescribed limit for filing appeals before the High Courts as per CBDT Circular No. 21/2015), deserve to be dismissed as not pressed. The Tribunal noted that the Circular applies retrospectively to pending appeals. It was clarified that the substantial questions of law raised in the appeals, if any, are left open to be examined in future appropriate proceedings. The Revenue was granted liberty to move an application for recalling the order if any of the appeals fall under the exceptions mentioned in paragraph 8 of the Circular dated 10.12.2015. Consequently, the appeals were dismissed as not pressed in light of the CBDT Circular.
The Tribunal held that the appeals should be dismissed as not pressed, taking into account CBDT Circular No. 21/2015 and the fact that the tax effect in these appeals is less than Rs. 20 lakhs, which is the prescribed limit for filing appeals before the High Courts. The Tribunal clarified that the substantial questions of law raised in the appeals are left open to be examined in future appropriate proceedings. It also observed that if any appeal falls under the exceptions mentioned in the circular (e.g., constitutional validity, adverse rulings on Board's orders), the Revenue is at liberty to move an application for recalling the order. The ratio decidendi is that appeals with a tax effect below the prescribed monetary limits, as per the CBDT circular, should be dismissed as not pressed, unless specific exceptions apply.
The Tribunal held that the appeals should be dismissed as not pressed, taking into account CBDT Circular No. 21/2015 and the fact that the tax effect in these appeals is less than Rs. 20 lakhs, which is the prescribed limit for filing appeals before the High Courts. The Tribunal clarified that the substantial questions of law raised in the appeals are left open to be examined in future appropriate proceedings. It also observed that if any appeal falls under the exceptions mentioned in the circular (e.g., constitutional validity, adverse rulings on Board's orders), the Revenue is at liberty to move an application for recalling the order. The ratio decidendi is that appeals with a tax effect below the prescribed monetary limits, as per the CBDT circular, should be dismissed as not pressed, unless specific exceptions apply.
The High Court held that the appeals filed by the Revenue deserved to be dismissed as not pressed, taking note of CBDT Circular No. 21/2015 and the fact that the tax effect in the instant case was less than Rs. 20,00,000/-, which is the prescribed limit for filing appeals before the High Courts. The Court clarified that the substantial questions of law raised in the appeals, if any, were left open to be examined in future appropriate proceedings. The Court also observed that if the appeal fell under any of the exceptions mentioned in the Circular dated 10.12.2015, the Revenue would be at liberty to move an application for recalling the order. Accordingly, the appeals were dismissed as not pressed.
The Tribunal held that the instant appeals, having a tax effect less than Rs. 20 lac, which is below the prescribed monetary limit for filing appeals before the High Courts as per CBDT Circular No. 21/2015, deserve to be dismissed as not pressed. The circular applies retrospectively to pending appeals. The Tribunal clarified that the substantial questions of law raised in these appeals are left open to be examined in future proceedings. The Revenue was granted liberty to move an application for recalling the order if the appeal falls under any of the exceptions mentioned in the circular. The appeals were accordingly dismissed as not pressed.
The High Court held that in light of CBDT Circular No. 21/2015, which sets a monetary limit of Rs. 20,00,000/- for filing appeals before the High Court and applies retrospectively to pending appeals, the instant appeals, where the tax effect is less than Rs. 20 lac, are to be dismissed as not pressed. The court clarified that the substantial questions of law raised in these appeals are left open for examination in future appropriate proceedings. The Revenue was also granted liberty to move an application for recalling the order if the appeal falls under any of the exceptions mentioned in the circular.
The Tribunal held that the appeals filed by the Revenue are to be dismissed as not pressed, in light of CBDT Circular No. 21/2015 dated 10.12.2015. The circular specifies a monetary limit of Rs. 20,00,000/- for filing appeals before the High Court and directs that pending appeals below the specified tax limits may be withdrawn or not pressed. Since the tax effect in the instant appeals indisputably is less than Rs. 20 lac, they fall within the purview of this directive. The Tribunal clarified that the substantial questions of law raised in these appeals, if any, are left open to be examined in future appropriate proceedings. It was also observed that if any appeal falls under the exceptions mentioned in the circular (e.g., constitutional validity, Board's order held illegal, undisclosed foreign assets), the Revenue would be at liberty to move an application for recalling the order. The ratio decidendi is that appeals with a tax effect below the prescribed monetary limits in the CBDT circular should be dismissed as not pressed, unless they fall under specific exceptions.
The Tribunal held that the instant appeals, having a tax effect less than Rs. 20 lac, which is below the monetary limit prescribed for filing appeals before the High Courts as per CBDT Circular No. 21/2015, deserve to be dismissed as not pressed. The Tribunal clarified that the substantial questions of law raised in these appeals, if any, are left open to be examined in appropriate future proceedings. Furthermore, the Revenue was granted liberty to move an application for recalling the order if the appeal fell under any of the exceptions specified in the Circular dated 10.12.2015. The appeals were accordingly dismissed as not pressed based on the CBDT Circular.
The Tribunal held that the instant appeals, having a tax effect less than Rs. 20 lac, which is below the monetary limit prescribed for filing appeals before the High Courts as per CBDT Circular No. 21/2015, deserve to be dismissed as not pressed. The Tribunal clarified that the substantial questions of law raised in these appeals, if any, are left open to be examined in appropriate future proceedings. Furthermore, the Revenue was granted liberty to move an application for recalling the order if the appeal fell under any of the exceptions specified in the Circular dated 10.12.2015. The appeals were accordingly dismissed as not pressed based on the CBDT Circular.
The High Court held that the instant appeals, having a tax effect indisputably less than Rs. 20 lac, which is below the prescribed limit for filing appeals before the High Courts as per CBDT Circular No. 21/2015, deserved to be dismissed as not pressed. The Court clarified that the substantial questions of law raised in the appeals, if any, were left open to be examined in future appropriate proceedings. The Revenue was also granted liberty to move an application for recalling the order if the appeal fell under any of the exceptions mentioned in the circular. Consequently, the appeals were dismissed as not pressed in light of the CBDT Circular dated 10.12.2015.
The High Court held that the appeals, having a tax effect less than Rs. 20 lac, were to be dismissed as not pressed, in light of CBDT Circular No. 21/2015. The Court noted that the circular applies retrospectively to pending appeals. It clarified that the substantial questions of law raised in the appeals were left open for examination in future appropriate proceedings. The Revenue was granted liberty to move an application for recalling the order if the appeal fell under any of the exceptions mentioned in the circular, such as constitutional validity challenges, illegality of Board's orders, or undisclosed foreign assets. The ratio is that appeals with tax effect below prescribed monetary limits should be withdrawn or not pressed as per CBDT circulars, unless specific exceptions apply.
The High Court held that the instant appeals, having a tax effect indisputably less than Rs. 20 lac, which is below the prescribed limit for filing appeals before the High Courts as per CBDT Circular dated 10.12.2015, deserve to be dismissed as not pressed. The Court clarified that the substantial questions of law raised in these appeals, if any, are left open to be examined in an appropriate proceeding in the future. Furthermore, the Revenue was granted liberty to move an application for recalling the order if the appeal falls under any of the exceptions mentioned in the Circular dated 10.12.2015. Consequently, the appeals were dismissed as not pressed in light of the CBDT Circular.
The High Court held that the appeals filed by the Revenue were to be dismissed as not pressed, taking into account CBDT Circular No. 21/2015 and the fact that the tax effect in the instant case was indisputably less than Rs. 20 lac, which is the prescribed limit for filing appeals before the High Courts. The Court clarified that the substantial questions of law raised in the appeals, if any, were left open to be examined in an appropriate future proceeding. The Revenue was granted liberty to move an application for recalling the order if the appeal fell within any of the exceptions specified in the Circular dated 10.12.2015. The operative direction was to dismiss the appeals as not pressed.
The High Court held that the instant appeals, having a tax effect indisputably less than Rs. 20 lac (which is the prescribed limit for filing appeals before the High Court as per CBDT Circular No. 21/2015), deserved to be dismissed as not pressed. The Court noted that the Circular No. 21/2015, issued under Section 268A(1) of the Income-tax Act, 1961, applied retrospectively to pending appeals. The Court clarified that the substantial questions of law raised in the appeals, if any, were left open to be examined in future appropriate proceedings. Furthermore, the Revenue was granted liberty to move an application for recalling the order if the appeal fell under any of the exceptions mentioned in paragraph 8 of the Circular (e.g., constitutional validity, challenge to Board's orders, undisclosed foreign assets).
The High Court held that the appeals filed by the Revenue, where the tax effect is indisputably less than Rs. 20 lac (and thus less than the prescribed limit for filing appeals before the High Court), deserve to be dismissed as not pressed, in light of CBDT Circular No. 21/2015. The Court clarified that the substantial questions of law raised in these appeals, if any, are left open to be examined in appropriate future proceedings. The Revenue is granted liberty to move an application for recalling the order if the appeal falls within the exceptions specified in the Circular dated 10.12.2015. The appeals are accordingly dismissed as not pressed.
The Tribunal held that the instant appeals, with a tax effect indisputably less than Rs. 20 lac (which is the prescribed limit for filing appeals before the High Courts as per CBDT Circular No. 21/2015), deserve to be dismissed as not pressed. The Tribunal clarified that the substantial questions of law raised in the appeals, if any, are left open to be examined in future appropriate proceedings. It was further observed that if any appeal falls within the exceptions mentioned in the circular (e.g., constitutional validity, Board's order being illegal, revenue audit objection accepted, or additions relating to undisclosed foreign assets/bank accounts), the Revenue would be at liberty to move an application for recalling the order. Consequently, the appeals were dismissed as not pressed in light of the CBDT Circular dated 10.12.2015.
The Tribunal held that the appeals, with a tax effect indisputably less than Rs. 20 lac (which is the prescribed limit for filing appeals before the High Courts as per CBDT Circular No. 21/2015), deserved to be dismissed as not pressed. The Tribunal noted that the circular applies retrospectively to pending appeals. It clarified that the substantial questions of law raised in the appeals, if any, are left open for examination in future appropriate proceedings. The Revenue was granted liberty to move an application for recalling the order if the appeal fell under any of the exceptions mentioned in the circular (e.g., constitutional validity challenges, adverse judgments on Board's orders, revenue audit objections accepted, or additions relating to undisclosed foreign assets/bank accounts). Accordingly, the appeals were dismissed as not pressed.
The Tribunal held that the appeals, with a tax effect indisputably less than Rs. 20 lac (which is the prescribed limit for filing appeals before the High Courts as per CBDT Circular No. 21/2015), deserved to be dismissed as not pressed. The Tribunal noted that the circular applies retrospectively to pending appeals. It clarified that the substantial questions of law raised in the appeals, if any, are left open for examination in future appropriate proceedings. The Revenue was granted liberty to move an application for recalling the order if the appeal fell under any of the exceptions mentioned in the circular (e.g., constitutional validity challenges, adverse judgments on Board's orders, revenue audit objections accepted, or additions relating to undisclosed foreign assets/bank accounts). Accordingly, the appeals were dismissed as not pressed.
The Tribunal held that the appeals, with a tax effect less than Rs. 20 lac, should be dismissed as not pressed, in light of CBDT Circular No. 21/2015 dated 10.12.2015. The Circular, which applies retrospectively, sets a monetary limit of Rs. 20 lac for filing appeals before the High Court. The Tribunal noted that while the Circular has exceptions (para 8) and specific provisions for non-quantifiable tax effects (para 9), the present appeals did not fall under these exceptions and had a quantifiable tax effect below the prescribed limit. The Tribunal clarified that substantial questions of law, if any, are left open for future proceedings and that the Revenue is at liberty to move an application for recalling the order if the appeal falls under any of the exceptions mentioned in the Circular. The operative direction is the dismissal of the appeals as not pressed.
The Tribunal held that the appeals, with a tax effect less than Rs. 20 lac, should be dismissed as not pressed, in light of CBDT Circular No. 21/2015 dated 10.12.2015. The Circular, which applies retrospectively, sets a monetary limit of Rs. 20 lac for filing appeals before the High Court. The Tribunal noted that while the Circular has exceptions (para 8) and specific provisions for non-quantifiable tax effects (para 9), the present appeals did not fall under these exceptions and had a quantifiable tax effect below the prescribed limit. The Tribunal clarified that substantial questions of law, if any, are left open for future proceedings and that the Revenue is at liberty to move an application for recalling the order if the appeal falls under any of the exceptions mentioned in the Circular. The operative direction is the dismissal of the appeals as not pressed.
The High Court held that the instant appeals, with a tax effect indisputably less than Rs. 20 lac (which is less than the limit prescribed for filing appeals before the High Courts), deserved to be dismissed as not pressed, in light of CBDT Circular dated 10.12.2015. The Court clarified that the substantial questions of law raised in the appeals, if any, were left open to be examined in an appropriate proceeding if they arise in the future. The Court also observed that if an appeal falls within any of the exceptions mentioned in the Circular dated 10.12.2015, the Revenue would be at liberty to move an application for recalling the order if so advised. Accordingly, the appeals were dismissed as not pressed.
The Tribunal held that the instant appeals, with a tax effect less than Rs. 20 lac, deserved to be dismissed as not pressed, in light of CBDT Circular No. 21/2015. The Tribunal noted that the circular applies retrospectively to pending appeals. It was clarified that substantial questions of law raised in these appeals are left open for examination in future proceedings. Furthermore, the Revenue was granted liberty to move an application for recalling the order if any of the appeals fell under the exceptions specified in the circular (e.g., constitutional validity, challenge to Board's order, audit objections accepted, or undisclosed foreign assets/bank accounts). The operative direction was to dismiss the appeals as not pressed.
The High Court held that the appeals filed by the Revenue, with a tax effect less than Rs. 20 lac, deserved to be dismissed as not pressed, in light of CBDT Circular No. 21/2015. The Court noted that the circular applies retrospectively to pending appeals. The Court clarified that the substantial questions of law raised in the appeals, if any, are left open to be examined in future proceedings. The Revenue was granted liberty to move an application for recalling the order if the appeal fell under any of the exceptions mentioned in the circular. Consequently, the appeals were dismissed as not pressed.
The High Court held that the instant appeals, with a tax effect indisputably less than Rs. 20 lac (and much less than the prescribed limit for High Court appeals), deserved to be dismissed as not pressed, in light of CBDT Circular dated 10.12.2015. The Court clarified that the substantial questions of law raised in the appeals, if any, were left open to be examined in future appropriate proceedings. It was also observed that if an appeal fell under any of the exceptions mentioned in the Circular (e.g., constitutional validity, Board's order held illegal, undisclosed foreign assets), the Revenue would be at liberty to move an application for recalling the order. Accordingly, the appeals were dismissed as not pressed.
The Tribunal held that the appeals, with a tax effect less than Rs. 20 lac, should be dismissed as not pressed, in light of CBDT Circular No. 21/2015. The Circular mandates that appeals shall not be filed where the tax effect does not exceed specified monetary limits, including Rs. 20 lac for High Court appeals. The Tribunal noted that the Circular applies retrospectively to pending appeals. However, it clarified that substantial questions of law, if any, are left open for examination in future proceedings. The Revenue was granted liberty to move an application for recalling the order if the appeal falls under any of the exceptions mentioned in the Circular, such as constitutional validity challenges or issues relating to undisclosed foreign assets/bank accounts.
The Tribunal held that the appeals, with a tax effect less than Rs. 20 lac, should be dismissed as not pressed, in light of CBDT Circular No. 21/2015. The Circular mandates that appeals shall not be filed where the tax effect does not exceed specified monetary limits, including Rs. 20 lac for High Court appeals. The Tribunal noted that the Circular applies retrospectively to pending appeals. However, it clarified that substantial questions of law, if any, are left open for examination in future proceedings. The Revenue was granted liberty to move an application for recalling the order if the appeal falls under any of the exceptions mentioned in the Circular, such as constitutional validity challenges or issues relating to undisclosed foreign assets/bank accounts.
The High Court held that the instant appeals, with a tax effect indisputably less than Rs. 20 lac (which is the prescribed limit for filing appeals before the High Courts as per CBDT Circular No. 21/2015), deserve to be dismissed as not pressed. The Court noted that the circular applies retrospectively to pending appeals. It clarified that the substantial questions of law raised in the appeals, if any, are left open to be examined in future appropriate proceedings. The Court also observed that if any appeal falls within the exceptions mentioned in the circular (e.g., constitutional validity, Board's order being illegal, revenue audit objection accepted, or undisclosed foreign assets/bank accounts), the Revenue is at liberty to move an application for recalling the order. Accordingly, the appeals were dismissed as not pressed in light of the CBDT Circular dated 10.12.2015.
The Tribunal held that the appeals, with a tax effect less than Rs. 20 lac, should be dismissed as not pressed, in light of CBDT Circular No. 21/2015 dated 10.12.2015. The circular sets a monetary limit of Rs. 20 lac for filing appeals before the High Courts. The Tribunal noted that the circular applies retrospectively to pending appeals. While dismissing the appeals as not pressed, the Tribunal clarified that the substantial questions of law raised are left open for examination in future proceedings. The Revenue was granted liberty to move an application for recalling the order if the appeal falls under any of the exceptions mentioned in the circular, such as challenges to constitutional validity or adverse judgments on Board's orders, instructions, or circulars, or issues relating to undisclosed foreign assets/bank accounts.
The Tribunal held that the instant appeals, having a tax effect less than Rs. 20 lac, which is below the prescribed monetary limit for filing appeals before the High Courts as per CBDT Circular No. 21/2015, deserve to be dismissed as not pressed. The Tribunal clarified that the substantial questions of law raised in these appeals are left open to be examined in future proceedings if they arise. It was also observed that if any appeal falls within the exceptions mentioned in the circular (e.g., constitutional validity, challenging Board's order, revenue audit objection accepted, or undisclosed foreign assets/bank accounts), the Revenue is at liberty to move an application for recalling the order. The operative direction was to dismiss the appeals as not pressed.
The Tribunal held that the instant appeals, with a tax effect indisputably less than Rs. 20 lac (which is the prescribed limit for filing appeals before the High Courts as per CBDT Circular No. 21/2015), deserve to be dismissed as not pressed. The Tribunal noted the retrospective application of the circular to pending appeals. However, it made it clear that the substantial questions of law raised in the appeals, if any, are left open to be examined in future appropriate proceedings. Furthermore, the Tribunal observed that if the appeal falls under any of the exceptions mentioned in the circular (e.g., constitutional validity challenges, adverse judgments on Board's orders, revenue audit objections accepted, or additions relating to undisclosed foreign assets/bank accounts), the Revenue is at liberty to move an application for recalling the order. Accordingly, the appeals were dismissed as not pressed in light of the CBDT Circular dated 10.12.2015.
The High Court held that the instant appeals, with a tax effect indisputably less than Rs. 20 lac (which is the prescribed limit for filing appeals before the High Courts), deserve to be dismissed as not pressed, in light of CBDT Circular dated 10.12.2015. The Court clarified that the substantial questions of law raised in the appeals, if any, are left open to be examined in future appropriate proceedings. Furthermore, the Court observed that if an appeal falls within any of the exceptions mentioned in the circular, the Revenue would be at liberty to move an application for recalling the order. Consequently, the appeals were dismissed as not pressed.
The Tribunal held that the instant appeals, having a tax effect indisputably less than Rs. 20 lac, which is the prescribed monetary limit for filing appeals before the High Courts as per CBDT Circular No. 21/2015 dated 10.12.2015, deserve to be dismissed as not pressed. The Circular applies retrospectively to pending appeals. The Tribunal clarified that substantial questions of law raised in these appeals, if any, are left open for examination in appropriate future proceedings. It was also observed that if an appeal falls under any of the exceptions mentioned in the Circular (e.g., constitutional validity, Board's order held illegal, audit objection accepted, or undisclosed foreign assets/bank accounts), the Revenue is at liberty to move an application for recalling the order. Accordingly, the appeals were dismissed as not pressed.
The Tribunal held that the appeals should be dismissed as not pressed in light of CBDT Circular dated 10.12.2015. The circular, which applies retrospectively to pending appeals, sets a monetary limit of Rs. 20,00,000/- for filing appeals before the High Court. Since the tax effect in the present appeals is indisputably less than this prescribed limit, the appeals are not maintainable under the revised guidelines. The Tribunal clarified that substantial questions of law, if any, are left open for examination in appropriate future proceedings. It also noted that if an appeal falls under the exceptions mentioned in the circular (e.g., constitutional validity, challenging Board's orders, audit objections accepted, or undisclosed foreign assets), the Revenue is at liberty to move an application for recalling the order. The operative direction is that the appeals stand dismissed as not pressed.
The Tribunal held that the instant appeals, having a tax effect indisputably less than Rs. 20 lac, which is the prescribed monetary limit for filing appeals before the High Courts as per CBDT Circular No. 21/2015 dated 10.12.2015, deserve to be dismissed as not pressed. The Circular applies retrospectively to pending appeals. The Tribunal clarified that substantial questions of law raised in these appeals, if any, are left open for examination in appropriate future proceedings. It was also observed that if an appeal falls under any of the exceptions mentioned in the Circular (e.g., constitutional validity, Board's order held illegal, audit objection accepted, or undisclosed foreign assets/bank accounts), the Revenue is at liberty to move an application for recalling the order. Accordingly, the appeals were dismissed as not pressed.