2026 (7) TMI 140

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....019 (arising out of ITA No. 1829/Ahd/2016 for AY 2011-12), whereby the miscellaneous application filed under Section 254(2) of the Income Tax Act, 1961 (for short, "the Act") by the Revenue, seeking rectification of the original order dated 16.11.2018 came to be rejected. 2. Learned Senior Standing Counsel Mr. Sanghani, appearing for the petitioner department, at the outset, has submitted that the Tribunal fell in error in interpreting Clause 10(e) of the Circular dated 11.07.2018, as modified by the Circular dated 20.08.2018. It is submitted that the Tribunal has held that there is no reference of any State Government Agencies such as Sales tax department or Value Added Tax (for short 'VAT') department and therefore, would not fall with....

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....at State law enforcement agencies are not referred under Clause 10(e) of the Circular dated 11.07.2018 read with Circular dated 20.08.2018. 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 16.11.2018 passed in ITA No. 1829/AHD/2016, the appeal came to be disposed of by the Tribunal on the ground of low tax effect, applying the monetary limit of Rs. 20 lakhs prescribed for filing appeals before the Tribunal. The Tribunal placed reliance on the Circular dated 11.07.2018 read with the Circular dated 20.08.2018 and di....