Assessee-company was engaged in business of trading iron ore. On basis of report of enquiry Commission, Assessing Officer found that assessee was one of such companies which quoted export price lesser than base value.   Assessing Officer,  made an addition on basis of aforesaid report of enquiry Commission.  Tribunal held that when assessee had purchased ‘royalty paid’ iron ore from open market and exported same at ALP, no addition could be made to assessee’s income on basis of aforesaid report.  High Court  held that Tribunal having taken into consideration applicability of report of enquiry Commission, findings recorded by Tribunal could not be interfered with.  Special Leave Petition against said impugned order was dismissed on ground of low tax effect.  Revenue filed a Miscellaneous Application against said order and pointed out that present should be treated as an exception under relevant Circular issued by Ministry of Finance.  There was threshold limit for proceeding under section 147 but this was only trigger point for initiating necessary proceedings against assessee in due course. Three weeks time was granted to get further instructions was to be granted to both assessee and revenue as jointly prayed for.   (PCIT v. Rawmin Mining and Industries (P.) Ltd(SLP (C) No. 12639 /2020 (2021) 124 taxmann.com 239 (SC)  (AY. 2010-11)