The Revenue contended that its appeals were maintainable despite the tax effect being below Rs. 50 lakhs on the ground that the additions were based on information received from external law-enforcement agencies and fell within exceptions subsequently introduced by letter dated 20-8-2018 modifying CBDT Circular No. 3/2018. The High Court held that the modification expressly operated from the date of its issue and the additional exceptions could not be given retrospective effect. The increased monetary limit, however, applied to pending appeals and appeals instituted before 20-8-2018 having tax effect below Rs. 50 lakhs were liable to be disposed of.