Section 120.(1). 1

The Commissioner may, on the recommendations of the
Council, from time to time, issue orders or instructions or directions
fixing such monetary limits, as he may deem fit, for the purposes of
regulating the filing of appeal or application by the officer of the State
tax under the provisions of this Chapter.
(2) Where, in pursuance of the orders or instructions or directions
issued under sub-section (1), the officer of the State tax has not filed
an appeal or application against any decision or order passed under
the provisions of this Act, it shall not preclude such officer of the State
tax from filing appeal or application in any other case involving the
same or similar issues or questions of law.
(3) Notwithstanding the fact that no appeal or application has been
filed by the offi cer of the State tax pursuant to the orders or
instructions or directions issued under sub -section (1), no person,
being a party in appeal or application shall contend that the officer of
the State tax has acquiesced in the decision on the disputed issue by
not filing an appeal or application.
(4) The Appellate Tribunal or court hearing such appeal or application
shall have regard to the circumstances under which appeal or
application was not filed by the officer of the State tax in pursuance
of the orders or instructions or directions issued under sub -section
(1).
Non appealable decisions and orders.-
121.Notwithstanding anything to the contrary in any provisions of
this Act, no appeal shall lie against any decision taken or order passed
by an officer of State tax if such decision taken or order passed relates
to any one or more of the following matters, namely:-
(a) an order of the Commissioner or other authority empowered to
direct transfer of proceedings from one officer to another officer; or
(b) an ord er pertaining to the seizure or retention of books of
account, register and other documents; or
(c) an order sanctioning prosecution under this Act; or
(d) an order passed under section 80.