Low tax effect bars Revenue appeal where Investigation Wing information does not fit the CBDT external-agency exception.

The Revenue's appeal was treated as not maintainable because the tax effect was below the CBDT monetary limit. The exception for additions based on information from external law enforcement agencies did not apply, as the material relied on came from the Department's Investigation Wing and was not treated as external law enforcement information. The later CBDT circular also did not assist the Revenue on the facts, so the appeal remained barred by the low tax effect.

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Issues: Whether the Revenue's appeal was maintainable in view of the low tax effect and the exception in the CBDT circular relating to additions based on information from external sources in the nature of law enforcement agencies.

Analysis: The tax effect in the appeal was below the monetary limit prescribed by the CBDT circular. The addition made by the Assessing Officer was based on information received from the Department's Investigation Wing, which was not treated as information from an external law enforcement agency of the kind contemplated in the exception clause. The exception was therefore held inapplicable, and the later circular also did not assist the Revenue on the facts of the case.

Conclusion: The Revenue's appeal was held to be not maintainable because the tax effect did not cross the prescribed monetary limit and no exception applied.

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