Assignment Problem (Principles of Taxation, LL.M Corp. Law I sem.

)
The Department of Revenue, Government of India has issued a circular on 15
July 2018 for filling the appeal before various judicial authorities. The Circular
says that to file an appeal to ITAT the tax liability should not be less than 20
lakhs, for High courts it should be 50 Lakhs and for Supreme Court it should be
1 crore. This Circular has been given the retrospective effect. It means all the
pending cases before these authorities will be withdrawn if threshold is bellow
the limit prescribed. One NGO has filled the Writ Petition before Hon’ble
Supreme Court to quash the circular being unconstitutional and ultra vires to
the power under Income Tax Act, 1961. It was submitted before the Hon’ble
Court that it is against the public policy and there will be loss of revenue to the
Government.
Kindly argue the Issue from both the side with appropriate reasoning and case
laws on this.