(1.) THE assessee preferred an appeal against an order passed by the Commissioner in exercise of power under Section 263 of the Income Tax Act, hereinafter referred to as the said Act. The learned Tribunal dismissed the appeal holding as follows:
(2.) AGGRIEVED by the order of the learned Tribunal, the assessee has come up in appeal.
(3.) HE also drew our attention to a Circular No. 762 dated 18th February, 1998 issued by the CBDT in connection with Finance (No. 2) Act, 1996 -Explanatory Notes on provisions relating to Direct Taxes. He relied on paragraph 23.2 of the aforesaid Circular, which reads as follows: