2019 (6) TMI 1059

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..... 7; 50,00,000/- for the Department to pursue the matter. Furthermore, the Revenue has not been able to point out any distinguishing features, by which the Circular No.3 of 2018, dated 11.07.2018, cannot be applied. Thus Revenue cannot pursue this Appeal in view of the low tax effect. Hence, the Appeal is dismissed and the Substantial Questions of Law, framed for consideration, are left open. .....

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..... on the following Substantial Questions of Law: (i)Whether, on the facts and circumstances of the case, the Income Tax Appellate Tribunal was right in holding that the Assessing Officer could not make a disallowance under Section 14A in the impugned assessment without noticing that the proviso to Section 14A applies only to making a reassessment under Section 147 of the Act and do .....

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..... as Rs. 50,00,000/- for the Department to pursue the matter. Furthermore, the Revenue has not been able to point out any distinguishing features, by which the Circular No.3 of 2018, dated 11.07.2018, cannot be applied. 5.Thus, for the above reasons, the Revenue cannot pursue this Appeal in view of the low tax effect. Hence, the Appeal is dismissed and the Substantial .....

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