PCIT v. Denisha Rajendra Keshwani. (2022) 285 Taxman 107 (Guj.)(HC)

S. 268A : Appeal-Application-Reference-Instructions-CBDT Circular No. 23/2019, dated 6-9-2019 and Office Memorandum No. 279, dated 16-9-2019 both providing that cases involving organized tax evasion scam through bogus long-term capital gain/short-term capital loss on penny stocks are not subject to monetary limits prescribed for filing appeals, would apply prospectively to appeals filed on or after 16-9-2019. [S. 260A]

Held that CBDT Circular No 23/2019 dated 6-9-2019   and Office Memorandum No. 279, dated 16-9-2019 issued by CBDT both providing that cases involving organized tax evasion scam through bogus long-term capital gain/short-term capital loss on penny stocks are not subject to monetary limits prescribed for filing appeals, would apply prospectively to appeals filed on or after 16-9-2019.