2019 (12) TMI 872

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..... he same leading to escapement of income - borrowed satisfaction - non independent application of mind by AO - HELD THAT:- The tax effect in the present matter being less than two crores, in view of the CBDT Circular dated 8.8.2019, we see no reason to interfere. The special leave petition is dismissed. We however, left all questions of law open to be considered in an appropriate matter. - Spe .....

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