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Since the tax effect involved in this matter is less than Rs. 2 crores, we see no reason to interfere in this matter. The special leave petition is dismissed, leaving all the questions of law open.

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Section 268A of the Income Tax Act, 1961 — Filing of appeal or application for reference by income tax authorities— SLP dismissed against High Court's order holding that revenue's appeal in respect of applicability of provisions of section 44C was not maintainable due to low tax effect — Commissioner of income tax vs. Hongkong and Shanghai Banking Corpn. Ltd. [2019].267 Taxman 501(SC)

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