2014 (11) TMI 649

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....espondent : Mr. Atul Jasani ORDER P. C. We have heard Mr.Sureshkumar appearing in support of these Appeals and Mr.Jasani for the Assessee to oppose. 2. When these Appeals were placed for admission, Mr.Jasani invited our attention to the Circular issued by the Government of India, Ministry of Finance, Department of Revenue, Central Board of Direct Taxes, being Instruction No.3/2011, dated 9th F....

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.... As usual apprehension of the Revenue is that in the event the Appeal is dismissed only on this count and relying on the Circular, it would be construed that the discussion and reasoning of the Tribunal has met with this Court's approval. It would also mean that the order of the Tribunal has been upheld by this Court. 5. We are sorry to say that such understanding defeats the Circular itself.....