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    <title>2023 (10) TMI 1348 - ITAT RAIPUR</title>
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    <description>ITAT Raipur recalled its earlier order dismissing revenue&#039;s appeal on low tax effect grounds. The case involved undisclosed income additions under section 69A made substantively against one assessee and protectively against another based on CBI information. Initially, the appeal was dismissed applying CBDT Circular 3/2018 due to minimal tax effect. However, on rectification, the Tribunal held that exception clause 10(e) of the circular applied since additions were based on CBI information from external law enforcement agencies. The Tribunal directed fresh adjudication on merits, accepting revenue&#039;s contention that such cases must be contested regardless of monetary limits when involving information from agencies like CBI/ED/DRI.</description>
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    <pubDate>Thu, 19 Oct 2023 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=311900</link>
      <description>ITAT Raipur recalled its earlier order dismissing revenue&#039;s appeal on low tax effect grounds. The case involved undisclosed income additions under section 69A made substantively against one assessee and protectively against another based on CBI information. Initially, the appeal was dismissed applying CBDT Circular 3/2018 due to minimal tax effect. However, on rectification, the Tribunal held that exception clause 10(e) of the circular applied since additions were based on CBI information from external law enforcement agencies. The Tribunal directed fresh adjudication on merits, accepting revenue&#039;s contention that such cases must be contested regardless of monetary limits when involving information from agencies like CBI/ED/DRI.</description>
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