2019 (4) TMI 837

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.... 1. Revenue is in the appeal against the judgment of the Income Tax Appellate Tribunal ("the Tribunal" for short). 2. Following question is formulated in the appeal for our consideration:- Whether on the facts and circumstances of the case and in law, the Tribunal was right in not confirming the disallowance of Rs. 48,11,915/- to book profit as per clause (f) to Explanation 1 u/S. 115JB of t....

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....on 268A, the CBDT is empowered to issue orders, instructions or directions to the Income Tax Authorities, fixing such monetary limits as it may deed fit, for the purpose of regulating filing of appeal or application for reference by any Income Tax Authority under the provisions of Chapter XX of the Act pertaining to appeal or application for reference. Sub-section (2) of Section 268A of the Act pr....

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....onetary limits for filing an appeal or application for reference shall be deemed to have been issued under sub-section (1) and the provisions of subsections (2), (3) and (4) shall apply accordingly. 4. Section 268A of the Act, thus, makes significant provisions in furtherance of the government's litigation reduction policy. Sub-section (1) of Section 268A as noted above empowers the Board t....

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....lowing:- "...... However, in case of a composite order of any High Court or appellate Authority, which involves more than one assessment year and common issues in more than one assessment year, appeals shall be filed in respect of all such assessment years even if the tax effect is less than the prescribed monetary limits in any of the year(s), if it is decided to file appeal in respect of the ....