2006 (8) TMI 122

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....001, passed by the Income-tax Appellate Tribunal, Mumbai, and raised the following substantial question of law: "Whether, on the facts and in the circumstances of the case and in the law, the Tribunal is correct in dismissing the appeal of the Revenue and confirming the order of the Commissioner of Income-tax (Appeals) as regards the expenses claimed by the assessee for earning the incentive bo....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....lowed by this court in CIT v. Pitthwa Engg. Works [2005] 276 ITR 519 and held that it is not open for the Department to contend that this circular is binding only with respect to new cases and not with respect to old cases even if the tax is less than Rs. 2 lakhs. The same policy for old matters needs to be adopted by the Department. The above instructions dated March 27, 2000, reflect the poli....