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TMI BlogThreshold set for monetary limits in filing appeals by Revenue: A policy shift towards reducing litigation and financial burden on the judiciary and taxpayersX X X X Extracts X X X X X X X X Extracts X X X X ..... on The intersection of administrative instructions and statutory provisions in the realm of tax litigation presents a complex matrix for legal interpretation and policy formulation. A deep dive into a particular High Court appeal concerning the Assessment Year 1993-94, revolving around the application of the Central Board of Direct Taxes (CBDT) Instruction No.3 of 2011 , offers a fertile groun ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... imits in filing appeals. Subsequent Revisions : Periodic revisions reflect a policy shift towards reducing litigation and financial burden on the judiciary and taxpayers. National Litigation Policy (2009) : A crucial backdrop, emphasizing efficient litigation practices and aiming to cut down on unnecessary legal disputes involving the government. Detailed Judicial Interpr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... involving low tax effects. In-Depth Analysis of the Court's Rationale in the Case Statutory Nature of CBDT Instructions : The Court viewed these instructions as an extension of the statutory framework, thereby making them binding on the Revenue Department. This interpretation places administrative instructions on a quasi-legislative pedestal, enhancing their legal gravitas. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... implications. This may lead to a more selective approach in pursuing appeals. Judicial Efficiency : By discouraging appeals in low-stake cases, courts can allocate resources more effectively to more substantial and complex legal disputes. Taxpayer Relief : Such interpretations provide relief to taxpayers, especially in cases where the cost of litigation might outweigh the tax ..... X X X X Extracts X X X X X X X X Extracts X X X X
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