That though the Departmental authorities were directed by the notification dated August 8, 2019  of the Central Board of Direct Taxes not to file appeal before the High Court where the monetary limit was less than Rs. 1 crore, but in the notification of the Board dated July 11, 2018  there was an exception to the effect that if there was a valid question, where an order, notification, instruction or circular was to be challenged as illegal or ultra vires, an appeal could be filed before the High Court on the merits notwithstanding the fact that the tax effect entailed was less than Rs. 1 crore. No such exception was available to the Department. Court also held that the Tribunal did not err in holding that the issue could not be decided under section 254(2) and the only remedy was to file appeal under section 260A before the High Court. (AY. 1996-97 to 1999-2000)