The Central Board of Direct Taxes issued Circular No. 3 of 2018 dated July 11, 2018 ([2018] 405 ITR (St.) 29) which was amended by Circular No. 5 of 2019, dated February 5, 2019 ([2019] 411 ITR (St.) 7) and Circular No. 17 of 2019, dated August 8, 2019 ([2019] 416 ITR (St.) 106). Circular No. 17 of 2019, substituted paragraph 5 of Circular No. 3 of 2018 dated July 11, 2018 with regard to the monetary limits prescribed. This circular does not distinguish the order passed under section 263 of the Income-tax Act, 1961 which pertains to the invocation of revisional powers of the Commissioner for revising assessment orders which are erroneous or prejudicial to the interests of the Revenue or any other section of the Act but it refers to the monetary limits prescribed in the circular itself and if any appeal is filed, which is not a writ matter, the monetary limits prescribed under the circular would apply and the Department is bound by such monetary limits and accordingly, the Department cannot pursue the matter, if the monetary limit prescribed in the circular is adhered to. The Tribunal quashed and set aside the orders passed by the Commissioner under section 263 against the assessee. The Department contended that the circular would not be applicable to appeals that arose from an order under section 263. On appeal dismissing the appeals, that even if the consolidated tax effect in all these appeals was taken, it would not exceed the monetary limits prescribed in Board’s Circular No. 17 of 2019 dated August 8, 2019 (2019) 416 ITR 106 (St,)  and therefore, the appeals were to be dismissed due to low tax effect.