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TMI Blog2020 (10) TMI 129X X X X Extracts X X X X X X X X Extracts X X X X ..... appeals by the Department before the ITAT has been increased to Rs. 50,00,000/- from Rs. 20,00,000/-. 3. In the rival submissions the Ld. JCIT DR submitted that the Circular No. 17/2019 : dt. 08/08/2019 is not clearly retrospective in as much as it specifically states in para 4 that " the said modification shall come into effect from the date of issue of this Circular" It was stated that the aforesaid sentence clearly gives an impression that the said Circular is applicable after the date mentioned there in and thereafter the departmental appeals which come in the specified tax effect limit will not be filed. The Ld. Counsel for the Assessee vehemently opposed the contention of the Ld. JCIT(DR) and said that the Circular must be held to h ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ,000 50,00,000 Before High Court 50,00,000 1,00.00.000 Before Supreme Court 1,00,00,000 2.00.00,000 * The Assessing Officer shall calculate the tax effect separately for every assessment year in respect of the disputed issues in the case of every assessee. If, in the case of an assessee, the disputed issues arise in more than one assessment year, appeal can be filed in respect of such assessment year or years in which the tax effect in respect of the disputed issues exceeds the monetary limit. No appeal shall be filed in respect of an assessment year or years in which the tax effect is less than the monetary limit * Further, even in the case of composite order of any High Court or appellate authority which involves mo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eals/cross objections/references to be filed henceforth in SCIHCs/Tribunal and it shall also apply retrospectively to pending SLPs/appeals/cross objections/references. Pending appeals below the specified tax limits in pare 3 above may be withdrawn/not pressed. 6. Now the CBDT simply enhanced the monitory limit and the directions given earlier vide para nos. 12 & 13 of the Circular no. 3/2018 dt. 11/07/2018 are still intact which is crystal clear from the language of the Circular no. 17/2019 wherein it has been mentioned that there is enhancement of monetary limit and amendment to Circular no. 3/2018 for reducing the litigation. We therefore are of the confirmed view that the amended Circular No. 17/2019 now issued by the CBDT is also appli ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... monetary limits specified in Para 3 of the Circular shall read as follows: S. No. Appeals/SLPs in Income-tax matters Monetary Limit (Rs.) 1 Before Appellate Tribunal 50,00,000 2 Before High Court 1,00,00,000 3 Before Supreme Court 2,00,00,000 3. Further, with a view to provide parity in filing of appeals in scenarios where separate order is passed by higher appellate authorities for each assessment year vis-à-vis where composite order for more than one assessment years is passed, para 5 of the circular is substituted by the following para: "5. The Assessing Officer shall calculate the tax effect separately for every assessment year in respect of the disputed issues in the case of every assessee. If in the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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