That though the Departmental authorities were directed by the notification dated August 8, 2019 of the Central Board of Direct Taxes not to file an appeal before the High Court where the monetary limit was less than Rs. 1 crore, but in the notification of the Central Board of Direct Taxes 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. (AY.1996-97 to 1999-2000)