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2020 (8) TMI 880

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....(Addl.CIT) Assessee by : Shri S.L. Poddar (Advocate) ORDER PER VIJAY PAL RAO, JM : By way of this Miscellaneous Application the revenue is seeking recalling of Tribunal's order dated 04.10.2019 whereby the appeal of the revenue was dismissed on the ground of low tax effect in view of the monetary limits provided in CBDT Circular No. 3 of 2018 dated 11.07.2018 which was revised by Circular ....

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....on has been filed by the revenue. Thus the ld. A/R has submitted that the assessee has right to raise the objection against validity of reopening of the assessment. 3. Having considered the rival submissions, at the outset, we note that the appeal of the revenue was dismissed being not maintainable due to low tax effect as per the monetary limits provided in the amended CBDT Circular No. 3 of 201....

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....cial assets)/undisclosed foreign bank account. (e) Where addition is based on information received from external sources in the nature of law enforcement agencies such as CBI/ED/DRI/SFIO/Directorate General of GST Intelligence (DGGI) (f) Cases where prosecution has been filed by the Department and is pending in the Court." As per clause (c) of para 10 of the Circular it is clear that where the....