2020 (1) TMI 1172

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....pondent. ORDER Heard. The tax effect in the present case is less than Rs. 2.00 lacs. Learned counsel for the appellant has argued before this Court that the appeal cannot be disposed of in view of CBDT circular dated 10.12.2015 read with circular dated 11.07.2018 as there is an audit objection. Learned counsel for the respondent has drawn the attention of this Court towards the judg....

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....d to be illegal or ultra vires, or (c) Where Revenue Audit objection in the case has been accepted by the Department, or (d) Where the addition relates to undisclosed foreign assets/bank accounts. 7. Mr. Pinto would submit that this is a conditional withdrawal permitted. The Revenues Circular, therefore, cannot be read de hors or by omitting this condition. One of the co....

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....he Circulars continue to bind the Revenue and if they contain any conditions, whether such conditions are attracted or not would have to be proved and established by the Revenue. Once there is no such record before us, we do not countenance the oral request of Mr. Pinto. Consequently, we do not see any reason to entertain this appeal. It is dismissed. Learned counsel for the appellant has merel....