2020 (8) TMI 262

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.... ORDER PER C.M.GARG,JM ITA No.214/CTK/2018 is directed against the order of the ld CIT(A)-2, Bhubaneswar dated 16.3.2018 for the assessment year 2014-15 in the matter of assessment u/s.144/147 of the Act. 2. ITA No.409/CTK/2018 is directed against the order of the ld CIT(A)-2, Bhubaneswar dated 14.9.2018 for the assessment year 2014-15 in the matter of penalty under section 271 of the A....

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....t, when the same is curable u/s.292BB of the Act. 3. On the facts and in the circumstances of the case, the Ld. CIT(A) is not justified in law as well as on facts in not considering the merits of the additions made by the AO and annulling the assessment order merely on technical grounds and on the basis of the judgements of various High Courts." 4. At the outset, ld A.R. of the assesse....

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..../- or less. 6. This circular, only enhances the monetary limits and gives further relaxation. The old circular, beyond any dispute or controversy, categorically applied to the pending appeals as on the date of issuance of circular. 7. The circular dated 8th August 2019 is not a standalone circular. It is to be read in conjunction with the CBDT circular No. 3/2018 (subsequent amendment theret....

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....of the appeal in the case: (i) in which it can be demonstrated that the appeals are covered by the exceptions, and (ii) which are inadvertently included in this bunch of appeals, wherein the tax effect, in terms of the CBDT circular (supra), exceeds Rs. 50,00,000. 10. We accept the request of ld D.R. We also make it clear that the appellant shall be at liberty to point out the....