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Rectification application rejected as assessee failed to raise issue of CIT(A)'s order lacking DIN before ITAT; assessee cannot rectify their own lapse. Addition upheld based on cash seized, not mere statement; CBDT instruction considered. Tax rate of 60% u/s 115BBE on undisclosed income upheld following precedent. Interest u/s 234A remanded to AO to allow adjustment of seized cash against tax liability before due date as per circular; interest u/s 234B decided. Relevant legal provisions, precedents, and reasoning provided.
Rectification application rejected as assessee failed to raise issue of CIT(A)'s order lacking DIN before ITAT; assessee cannot rectify their own lapse. Addition upheld based on cash seized, not mere statement; CBDT instruction considered. Tax rate of 60% u/s 115BBE on undisclosed income upheld following precedent. Interest u/s 234A remanded to AO to allow adjustment of seized cash against tax liability before due date as per circular; interest u/s 234B decided. Relevant legal provisions, precedents, and reasoning provided.
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