Selective filing of tax appeals directs deference to factual findings and personal pre appeal record review by senior officers. Selective filing of tax appeals is departmental policy to control litigation: factual findings by Commissioners (Appeals) should be accepted unless perverse, and appeals must not be authorised merely because revenue is large. Commissioners of Income Tax must personally examine records before authorising appeals and may consult Senior Departmental Representatives prior to authorisation.
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Provisions expressly mentioned in the judgment/order text.
Selective filing of tax appeals directs deference to factual findings and personal pre appeal record review by senior officers.
Selective filing of tax appeals is departmental policy to control litigation: factual findings by Commissioners (Appeals) should be accepted unless perverse, and appeals must not be authorised merely because revenue is large. Commissioners of Income Tax must personally examine records before authorising appeals and may consult Senior Departmental Representatives prior to authorisation.
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