CBDT Raises Monetary Threshold to ₹2 Crore for HC Appeals: Chhattisgarh HC Disposes of Revenue’s Appeal [Read Order]
The High Court disposed of the appeal, holding that in view of paragraph 5 of the circular which mandates withdrawal of pending appeals not meeting the monetary threshold the present tax case could not be entertained
The Chhattisgarh High Court has disposed of an income-tax appeal filed by the Revenue after the Department conceded that the case no longer met the revised monetary threshold prescribed by the Central Board of Direct Taxes ( CBDT ) for filing appeals before High Courts.
The Bench comprising Justice Rajani Dubey and Justice Amitendra Kishore Prasad noted that the tax effect in the case was below ₹2 crore, and therefore, according to CBDT’s latest litigation-management circular, the appeal could not be pursued.
The appeal was filed by the Principal Commissioner of Income Tax, Raipur-1, against M/s Aaryan Rice Industries LLP. When the matter was taken up, counsel for the Revenue informed the Court that the Ministry of Finance, Department of Revenue, had issued a fresh circular dated 17 September 2024, increasing the monetary limits for departmental appeals under Section 268A of the Income Tax Act. As per the revised norms, the threshold for filing appeals before High Courts has been increased from the earlier limit to ₹2 crore.
The Revenue submitted that since the tax effect in the present case fell below ₹2 crore, continuation of the appeal would be contrary to the CBDT’s new policy, aimed to reduce non-essential tax litigation and promote certainty in tax assessments.
The circular expressly mandates that the revised monetary limits apply not only to future appeals but also to those currently pending before High Courts and the Supreme Court, which must be withdrawn if they fall below the specified threshold.
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For clarity, the Court reproduced the relevant portions of the circular, which states the increased limits: ₹60 lakh for appeals to the ITAT, ₹2 crore for High Courts, and ₹5 crore for the Supreme Court.
The circular also stated that appeals should not be filed mechanically merely because tax effect exceeds the limit, instead, authorities must evaluate the merits while keeping in mind the overarching objective of reducing unnecessary litigation.
The Division Bench observed that the Revenue’s submission was fair and consistent with CBDT’s policy direction.
Consequently, the High Court disposed of the appeal, holding that in view of paragraph 5 of the circular which mandates withdrawal of pending appeals not meeting the monetary threshold the present tax case could not be entertained.
With this order, the High Court terminated the proceedings.
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