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ITAT dismissed the Revenue's appeal challenging AO's additions under sections 68/69/69A treating certain cash deposits as unexplained and applying section 115BBE at 60%, concluding the consequential tax effect is insufficient to sustain the appeal. The Tribunal held that the enhanced levy under section 115BBE applies only to transactions occurring on or after 01.04.2017, and therefore the AO's higher-tax computation was not tenable. Applying the CBDT Circular No. 09 of 2024 on low tax effect, the appeal was found to lack sufficient revenue consequence and was dismissed, leaving the assessment adjustments (as limited by applicable temporal scope and normal provisions) unupheld in favour of the Revenue.
ITAT dismissed the Revenue's appeal challenging AO's additions under sections 68/69/69A treating certain cash deposits as unexplained and applying section 115BBE at 60%, concluding the consequential tax effect is insufficient to sustain the appeal. The Tribunal held that the enhanced levy under section 115BBE applies only to transactions occurring on or after 01.04.2017, and therefore the AO's higher-tax computation was not tenable. Applying the CBDT Circular No. 09 of 2024 on low tax effect, the appeal was found to lack sufficient revenue consequence and was dismissed, leaving the assessment adjustments (as limited by applicable temporal scope and normal provisions) unupheld in favour of the Revenue.
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