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TMI Blog2025 (2) TMI 770X X X X Extracts X X X X X X X X Extracts X X X X ..... the parties. 2. Learned counsel for the assessees submit that the tax effect in these appeals is less than Rs. 50,00,000/-. They point out that these tax appeals were instituted before 28 August 2018 and, therefore, should be dismissed based, inter alia, on circulars dated 10 December 2015 and 11 July 2018. 3. Learned counsel for the respondent-Revenue, however, contest the above submission. They pointed out that when these appeals were instituted, the tax effect was beyond the monetary limits specified in Circular No. 21 of 2015 dated 10 December 2015. They submitted that even circular No. 3 of 2018 dated 11 July 2018 was modified/amended on 20 August 2018. 4. Mr Sharma contended that on a conjoint reading of the circular dated 11 July ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eed that these appeals do not fall within these exceptions. 9. Circular No. 3 of 2018 dated 11 July 2018 increased the monetary limits to Rs. 50,00,000/-. The exceptions were set out in paragraph 10. Again, it is not Revenue's case that these appeals fell within exceptions set out in paragraph 10 of the circular dated 11 July 2018. 10. Paragraph 13 of the circular dated 11 July 2108 is significant and is transcribed below for the convenience of reference:- "13. This Circular will apply to SLPs/appeals/ cross objections/ references to be filed henceforth in SC/HCs/ Tribunal and it shall also apply retrospectively to pending SLPs/ appeals/ cross objections/ references. Pending appeals below the specified tax limits in para 3 above may be ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the coordinate bench held that the monetary limits would apply to the pending appeals, but when it comes to the exceptions subsequently introduced, such exceptions could not be construed retrospectively. 15. The above decision was followed by us in Income Tax Appeal No. 643 of 2018 and connected matters disposed of on 05 February 2025 (The Principal Commissioner of Income Tax-23, Mumbai Vs. M/s IPL Loan Trust). Applying the same principles to the circulars and amending letters involved in the present appeals, we are satisfied that these four appeals which were instituted before 20 August 2018 would have to be disposed of as the tax effect involved in these appeals is below the monetary limits of Rs.50,00,000/-. 16. For all the above reas ..... X X X X Extracts X X X X X X X X Extracts X X X X
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