The Central Board of Direct Tax by circular no 17 of 2019 dated 08-08-2019, issued a direction that no appeal shall be filed before the Tribunal in case the tax effect does not exceed Rs 50 Lakhs. The appeal of the revenue did not exceed Rs. 50 lakhs and ought to be dismissed for low tax effect. Circular grants liberty to the parties to move the Tribunal if the case falls with the exceptions and to reinstate the matter.

The revenue received merit order of the Tribunal on 24-09-2014. The AO had levied the penalty u/s. 271(1)(c) on 27-01-2016. S.275(1)(a) provides penalty order to be passed within six months from the end of the month in which either party receives the order of the Tribunal. The order passed by the AO  is beyond the period of six months, thus barred by limitation. (AY. 2006-07,  2008-09)