2026 (4) TMI 775

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.... For the Petitioner(s) No. 1: Karan G Sanghani (7945). For the Respondent(s) No. 1: Mr B.S. Soparkar (6851). ORAL JUDGMENT (PER : HONOURABLE MR. JUSTICE A.S. SUPEHIA) 1. The present petition has been filed assailing the order dated 10.02.2021 passed by the Income Tax Appellate Tribunal, Surat Bench, Surat (for short, "the Tribunal") in MA No. 24/SRT/2020 (arising out of IT(SS)A No. 226....

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.... be considered as one of the agencies referred to in Clause 10(e) of the said circulars. Consequently, it is submitted that the case of the Revenue would fall within the exception provided therein and the monetary limit of Rs.20 lakhs, as prescribed in the circulars, would not apply to the present case. Thus, it is urged that the impugned judgment and order be quashed and set aside. 3. Per cont....

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....h No.5 of the Circular dated 17.09.2024. Thus, it is urged that the present petition be dismissed. 4. We have heard the learned advocates appearing for the respective parties at length. 5. We have also perused the impugned order dated 10.02.2021 passed by the Tribunal. It is not in dispute that by the order dated 23.08.2019 passed in IT(SS)A No. 226/AHD/2021, the appeal came to be disposed o....

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....cing reliance on the order of its Coordinate Bench at Mumbai in ITA Nos. 818-820/Mum/2017, rejected the miscellaneous application by holding that DGCEI is not a law enforcement agency and, therefore, would not be covered by paragraph 10(e) of the Circular dated 11.07.2018 read with the Circular dated 20.08.2018. We find that the Tribunal has committed an error in recording such a finding. 7. A ....