Low tax effect bar applies where DGIT (Inv.) information is not treated as law-enforcement source under CBDT exception.

The revenue's appeal was held not maintainable because the disputed addition was below the monetary limit prescribed for Tribunal appeals under CBDT Circular No. 17/2019. The attempt to invoke the paragraph 10(e) exception failed, as the reassessment was based on information from DGIT (Inv.), Mumbai, which was not treated as information from an external source in the nature of a law enforcement agency. Accordingly, the low tax effect bar applied and the exception did not save the appeal.

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Issues: Whether the revenue's appeal was maintainable in view of the low tax effect and whether the case fell within the exception under paragraph 10(e) of the CBDT circular concerning information received from external sources in the nature of law enforcement agencies.

Analysis: The disputed addition was only Rs. 9,45,000, which was below the monetary threshold of Rs. 50 lakh prescribed for appeals before the Tribunal under Circular No. 17/2019 dated 08.08.2019. The revenue sought to invoke paragraph 10(e) of the CBDT circular dated 20.08.2018, but the assessment was reopened on information received from the office of DGIT (Inv.), Mumbai. That source was not treated as an external source in the nature of a law enforcement agency such as CBI, ED, DRI, SFIO, or DGGI. The exception therefore did not apply.

Conclusion: The appeal was not saved by paragraph 10(e) of the CBDT circular and was not maintainable in view of the low tax effect.

Ratio Decidendi: Information received from DGIT (Inv.) does not constitute information from an external source in the nature of a law enforcement agency for the purpose of paragraph 10(e) of the CBDT circular on monetary limits for appeals.

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