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The impugned judgment is set aside and the appeals filed by the respondent before the High Court be treated as dismissed in terms of this order because of low tax effect, leaving questions of law open.

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Section 260A & 268A of the Income Tax Act, 1961 — Appeal to High Court — There was no possibility of a cascading effect nor was the issue involved in a group of matters as such, the judgement of the High Court was to be set aside and the Department's appeals before the High Court treated as dismissed because of low tax effect, leaving the questions of law open — SC Naregal vs. Commissioner of income tax [2019] 418 ITR 455 (SC)

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