JUDGMENT : Kurian, J. 1. We have heard learned counsel for the parties. 2. Delay condoned. 3. Since the tax effect is below Rs.25,00,000/- (rupees twenty five lacs only) at the time of filing of the civil appeal, in view of the circular issued by the Central Board of Direct Taxes, this civil appeal is dismissed. 4. However, the question of law is kept open. 5. I.A. No. 2 of 2016 for direction is disposed of.