2020 (10) TMI 1374

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..... BAD] - assessment framed u/s 147 relying on belief of CBI - as pleaded in the MA that case of the Revenue falls within the exception clause (e) of para-10 of the CBDT Circular i.e. proceedings in this case was taken up on the basis of external information i.e. CBI - HELD THAT:- As assessee did not dispute about this, and submitted that appeal of the assessee for this assessment year is pending .....

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..... 19 passed in ITA No.332/Ahd/2005 for A.Y.1996-97. 2. It is pleaded in the MA that case of the Revenue falls within the exception clause (e) of para-10 of the CBDT Circular i.e. proceedings in this case was taken up on the basis of external information i.e. CBI. The ld.counsel for the assessee did not dispute about this, and submitted that appeal of the assessee i.e. ITA No.435/Ahd/2005 for this .....

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