2024 (9) TMI 32

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..... of low tax effect. However, the question of law is left open Plea is founded on the Circular dated 28.08.2018 which sets out the circumstances where notwithstanding the low tax effect, the Revenue is required to contest the matter. More specifically the Revenue relies on the Clause (e) of the Circular, which reads as under:- (e) Where addition is based on information received from external source .....

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..... on of the SLP which was dismissed on 16.12.2022 on the ground of low tax effect. Now the miscellaneous application is filed for restoration of the SLP and the plea is founded on the Circular dated 28.08.2018 which sets out the circumstances where notwithstanding the low tax effect, the Revenue is required to contest the matter. More specifically the Revenue relies on the Clause (e) of the Circular .....

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