(2026: JHHC: 20900-DB) IN THE HIGH COURT OF JHARKHAND AT RANCHI T.A No. 27 of 2026 Principal Commissioner, Central Goods Service Tax & Central Excise, Ranchi (formerly Commissioner of Central Excise & Service Tax) having its office at 5-A, Central Revenue Building, M.G. Road, P.O & P.S. Lower Bazar, District-Ranchi, Jharkhand ... … Appellant / Respondent Versus M/s Data Alloys Limited having its office at A-1, Phase-IV, Industrial Area, P.O & P.S. Balidih, District Bokaro, Jharkhand ... Respondent / Appellant --------- CORAM: HON’BLE THE CHIEF JUSTICE HON’BLE MR. JUSTICE RAJESH SHANKAR --------- For the Appellant: Mr P.A.S. Pati, Sr. S.C --------- 02 / Dated: 15.07.2026 1. In this case, tax demand is Rs. 2,04,265/-. Since this demand is much less than the ceiling provided under the CBIC Circular for the Revenue to pursue such matters, we would have expected the Revenue to withdraw this appeal. 2. However, Mr Pati submits that the issue involved in this appeal relates to the constitutional validity of Rule 8(3A) of the Central Excise Rules, 2002 and would therefore fall within the exception in paragraph 2(a) of Instructions dated 02.11.2023. 3. An identical contention was raised by Mr Pati, Senior Standing Counsel for the Revenue in Tax Appeal Nos. 1 of 2022, 2 of 2022 and 14 of 2023. Such contention was however not accepted in the order dated 16.03.2026 by which the said three appeals were disposed of. 4. Therefore, by adopting the reasoning in the order dated 16.03.2026 disposing of the Tax Appeal No. 1 of 2022 and connected matters, we dispose of this appeal on the ground of low tax effect. However, the question of law raised in this appeal is left open. (M. S. Sonak, C.J.) (Rajesh Shankar, J.) July 15, 2026 N.A.F.R. Ranjeet/R.Kr./Cp.2 Uploaded on 17.07.2026