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Clause 10(e) of the CBDT circulars was interpreted as illustrative, not exhaustive, for identifying law enforcement agencies. The High Court held that DGCEI, being an enforcement agency, falls within that expression and could not be excluded merely because it was not named alongside CBI, ED, DRI, SFIO and DGGI. The Tribunal had therefore misread the circulars in rejecting the Revenue's rectification application under section 254(2), and that rejection could not stand. The impugned order was set aside, the rectification matter was restored to the Tribunal, and the issue was remanded for fresh decision after hearing both sides.
Clause 10(e) of the CBDT circulars was interpreted as illustrative, not exhaustive, for identifying law enforcement agencies. The High Court held that DGCEI, being an enforcement agency, falls within that expression and could not be excluded merely because it was not named alongside CBI, ED, DRI, SFIO and DGGI. The Tribunal had therefore misread the circulars in rejecting the Revenue's rectification application under section 254(2), and that rejection could not stand. The impugned order was set aside, the rectification matter was restored to the Tribunal, and the issue was remanded for fresh decision after hearing both sides.
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