2020 (5) TMI 147

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....er Dalal, Advocate for the Respondent.   P.C.:- 1. Heard Mr.A.K.Saxena, learned standing counsel, Revenue for the applicant/appellant; and Mr.Sameer Dalal, learned counsel for the respondent/assessee. 2. This interim application has been filed by the appellant for condoning the delay of 93 days in filing the present application and also to recall the order dated 3rd October, 2019, whereby ....

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....t. 5. It is stated that the related addition was made to the income of the assessee on the basis of information received from banking sources, Geneva, Switzerland. Therefore, the related appeal would be covered by the exceptions as provided in the CBDT Circular No.3 of 2018 dated 11th July, 2018. Instructions to that effect could not be communicated to learned counsel who appeared for the Revenue....