Supreme Court Dismisses Case Due to Low Tax Impact; Upholds High Court Ruling on Section 148 Notice.

The SC dismissed SLP No. 19275 of 2016 due to a low tax effect, aligning with Circular No. 17 of 2019. In SLP No. 24038 of 2016, the SC upheld the HC's decision, supporting the ITAT's 2013 ruling that set aside the AO/CIT's order related to a Section 148 notice. All pending applications were disposed of.

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Issues involved:
The issues involved in the judgment are the dismissal of Special Leave Petitions (SLPs) based on low tax effect and the legality of a notice issued under Section 148 of the Income Tax Act.

Regarding SLP No. 19275 of 2016:
In SLP No. 19275 of 2016, the learned senior counsel for the Revenue argued that the petition should be dismissed due to low tax effect, citing Circular No. 17 of 2019 issued by the Department of Revenue. Consequently, the Special Leave Petition was dismissed based on this submission.

Regarding SLP No. 24038 of 2016:
In SLP No. 24038 of 2016, the legality of a notice issued under Section 148 of the Income Tax Act was questioned. The notice dated 28.03.2008 was followed by an order passed by the AO/CIT, which was set aside by the Income Tax Appellate Tribunal in 2013. The Tribunal's decision was then upheld by the High Court in 2015, effectively concluding the proceedings initiated in 2008. Despite keeping the question of law open for future consideration, the Court decided not to interfere with the judgment of the High Court, ultimately dismissing the Special Leave Petition. Any pending applications were also disposed of as a result of this decision.

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