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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)