Director Of Income Tax New Delhi vs M/S S.R.M.B.Diary Farming (P) Ltd.

The Supreme Court addressed the implementation of Instruction No.3 of 2011 by the Income Tax Department, which stipulates that appeals should not be filed before High Courts where the tax impact is less than Rs.10 lakh. The Court clarified that this Instruction supersedes an earlier limit of Rs.4 lakh and has a prospective effect, meaning pending cases filed before the Instruction should be determined on their merits. The Court emphasized the need for responsible litigation to reduce docket explosion and guide High Courts to avoid conflicting orders regarding the application of this Instruction.