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Whether the Appellate Tribunal has erred in law and on facts in dismissing the appeal on the ground of low tax effect despite the fact that case falls under the exceptions laid out in the CBDT's Circular?

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Section 268A of the Income Tax Act, 1961 — Filing of appeal — Tribunal could not dismiss said appeal on ground of low tax effect as assessee's case was reopened on basis of audit objection, in such a case, revenue's appeal would be covered by exception mentioned in Circular No. 3/2018 — Principal Commissioner of income tax vs. Kunj Infrastructure P. Ltd. [2019] 266 Taxman 296 (Gujarat)

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