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TMI Blog2020 (12) TMI 67X X X X Extracts X X X X X X X X Extracts X X X X ..... et, submitted that the tax effect of quantum additions being agitated by the revenue is below the prescribed monetary limit of Rs. 50 Lacs and therefore the appeal is not maintainable in terms of recently issued low tax effect Circular No. 17/2019 dated 08/08/2019 [F.No.279/Misc. 142/2007-TTJ(Pt.) issued by CBDT. This recent circular further enhances the monetary limit fixed in earlier Circular No.3 of 2018 dated 11/07/2018 issued by CBDT as amended on 20/08/2018. 3. On the other hand, Ld. DR controverted the same by placing on record Assessing Officer's letter dated 24/09/2019. The concluding para of the said letter read as under: - iv. That as per the above provisions, the tax effect involved in the subject of appeal is below the presc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... om DDIT(Inv.), the assessee maintained one Bank Account with ICICI Bank, Nariman Point Branch and received foreign remittances of Rs. 132.70 Lacs in the said account. However, no return of income was filed by the assessee for year under consideration which resulted into initiation of reassessment proceedings against the assessee. Although the assessee made certain submissions to Ld. AO during the course of assessment proceedings, however, the same could not find favor with Ld. AO who ultimately added the said amount as unexplained money u/s 69A in the hands of the assessee. 5. During appellate proceedings, the assessee submitted certain additional evidences which were subjected to remand proceedings. After perusing the material on record, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... reshold monetary limit of Rs. 50 Lacs and the appeal is not maintainable in terms of recently issued low tax effect Circular No. 17/2019 dated 08/08/2019 [F.No.279/Misc. 142/2007- TTJ(Pt.) issued by CBDT. This recent circular further enhances the monetary limit fixed in earlier Circular No.3 of 2018 dated 11/07/2018 issued by CBDT as amended on 20/08/2018. In view of the same, the appeal is not maintainable. The investigation arm of the Income Tax Department is an internal organ of the department and therefore, the same would not fall under the category of external sources in the nature of law enforcement agencies as envisaged by clause 10(e) of the said circular. 7. At the same time, a liberty is given to revenue to seek recall of the app ..... X X X X Extracts X X X X X X X X Extracts X X X X
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