Facts of the
Case
The Revenue filed appeals before the Income Tax
Appellate Tribunal (ITAT), Allahabad Bench, challenging the orders passed by
the Commissioner of Income Tax (Appeals) in favour of the assessee for the
relevant assessment years. The appeals arose from additions and disallowances
made during assessment proceedings which were partly or fully deleted by the
CIT(A).
On scrutiny of the records, the Tribunal found that
the tax effect involved in each appeal was below the monetary limit prescribed
by the Central Board of Direct Taxes (CBDT) for filing departmental appeals
before the Tribunal.
Issues Involved
- Whether the Revenue’s appeals were maintainable when the tax effect
was below the threshold prescribed by CBDT.
- Whether the Tribunal should entertain departmental appeals contrary
to binding instructions issued under statutory authority.
Petitioner’s Arguments (Revenue)
The Revenue contended that the order of the CIT(A)
granting relief to the assessee was erroneous and that the additions made by
the Assessing Officer deserved to be restored. It was argued that the issues
involved were substantial and required adjudication on merits by the Tribunal.
Respondent’s Arguments (Assessee)
The assessee submitted that the appeals were not
maintainable as the tax effect in each case was below the monetary limit
prescribed by the CBDT for filing appeals before the ITAT. Therefore, the
appeals were liable to be dismissed at the threshold in accordance with the
Board’s instructions.
Court Order / Findings
The Tribunal observed that the CBDT has issued binding circulars prescribing monetary limits to regulate filing of departmental appeals with the objective of reducing unnecessary litigation.
As per the applicable circular, appeals before the
ITAT are not to be filed where the tax effect is below the specified monetary
threshold.
The Tribunal clarified that the tax effect
represents the difference between the tax on assessed income and the tax that
would have been chargeable if the disputed issues were excluded. Interest
components are generally not included unless the dispute specifically relates
to interest.
Since the tax effect in all the appeals filed by
the Revenue was below the prescribed limit, the Tribunal held that the appeals
were not maintainable.
Accordingly, the appeals of the Revenue were
dismissed in limine.
Important Clarification
The Tribunal clarified that dismissal of appeals on
the ground of low tax effect does not amount to adjudication on the merits of
the case. Such dismissal is in line with CBDT’s litigation-management policy
and does not prevent the Department from raising similar issues in other cases
where the tax effect exceeds the prescribed threshold or where exceptions
apply.
Link to download the order -https://itat.gov.in/public/files/upload/1545128171-VINDYAWASINI-509%20TO%20511%20(TAX).pdf
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