2022 (3) TMI 659

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....y, Sr (DR) ORDER PER C.M.GARG, JM This is an appeal filed by the revenue against the order of the CIT(A), Cuttack dated 18.09.2020 for the assessment year 2015-16. 2. The appeal is time barred by 111 days. The revenue filed condonaton petition to condone the delay in filing the appeal before the Tribunal, stating that the limitation to file appeal before the Tribunal has expired due to....

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.... appeal by the revenue is condoned and the appeal is admitted for adjudication. 4. The revenue is aggrieved by the order of the ld CIT(A) in deleting addition of Rs. 1,58,80,813/- from interest on fixed deposits made in the co-operative banks u/s. 80P(2)(a)(i)/80P(2)(d) of the I.T.Act. 5. At the outset, ld A.R. of the assessee submitted that in this case, the tax effect is below the monetary....

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....s 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. 8. 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 thereto), and all it does is to replace paragraph nos. 3 and 5 of the s....

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....emonstrated 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. 11. We accept the request of ld CIT D.R. We make it clear that the appellant shall be at liberty to point out the case which is wrongly included in the appeal so summarily di....