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of Applicability of special tax rate u/s 115BBE - income surrendered in search and seizure operation u/s 132 and offered in the return of income - Admittedly, assessee has not offered the income u/s 69A - Even, AO has not made any separate addition under Section 69A - He has merely re-characterized the nature of income offered by the assessee. - Higher Rate of Tax u/s 115BBE would not be applicable - AT
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