Monetary Threshold in Absence of Demonstrated Exceptional Circumstances

The Calcutta High Court in Principal Commissioner of Income Tax-2, Kolkata v. Ahinsha Management Private Limited dismissed a Revenue appeal on the ground that the tax effect involved was below the monetary threshold prescribed under the CBDT litigation management circulars. 

Although the Revenue attempted to invoke the exception clause contained in paragraph 3.1(h) of CBDT Circular No. 5 of 2024, the Court found that no specific exceptional circumstance had been properly demonstrated. 

The ruling reiterates the binding nature of CBDT monetary limit circulars and emphasizes that exceptions permitting appeals below threshold limits must be specifically pleaded and substantiated.