Tribunal  held that the thrust in the exception in para 10(e) of the circular No. 3 of 2018 dated 11-7-2018 [1] and modification dated 20-8-2018 issued by CBDT was that additions should be based on information received from “external sources” and secondly these external sources should be in the nature of “law enforcement agencies”. These two conditions were necessarily and mandatorily required to be fulfilled to be covered under the exception. Since these exceptions took away the benefit granted by the Department to the taxpayers by way of withdrawal of pending appeals with low tax effect, the onus was on the Department to show that the taxpayer’s case was covered by these exceptions and the taxpayer was not entitled to seek protection granted by the circular. These exceptions were penal in nature and were to be strictly construed. (AY. 2007-08, 2008-09 & 2010-11)