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    <title>2026 (3) TMI 1177 - ITAT CHENNAI</title>
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    <description>Where a declaration under the Income Declaration Scheme, 2016 was not paid within the specified time, the declaration is deemed never made and the declared amount constitutes undisclosed income chargeable to tax in the previous year in which the declaration was made; accordingly the addition as unexplained investment for Financial Year 2016-17 (Assessment Year 2017-18) is sustained. Separately, the enhanced higher tax rate introduced later is not retrospective, so the undisclosed income chargeable for FY 2016-17 must be taxed at the pre-amendment rate rather than the later higher rate.</description>
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      <description>Where a declaration under the Income Declaration Scheme, 2016 was not paid within the specified time, the declaration is deemed never made and the declared amount constitutes undisclosed income chargeable to tax in the previous year in which the declaration was made; accordingly the addition as unexplained investment for Financial Year 2016-17 (Assessment Year 2017-18) is sustained. Separately, the enhanced higher tax rate introduced later is not retrospective, so the undisclosed income chargeable for FY 2016-17 must be taxed at the pre-amendment rate rather than the later higher rate.</description>
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