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    <title>2025 (2) TMI 1907 - ITAT CHANDIGARH</title>
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    <description>Surrendered income linked to stock and loose papers found during survey was treated as business income, because the record did not show any unexplained investment or income from a source outside the timber and plywood business. In the absence of the deeming fiction under section 69, the enhanced tax rate under section 115BBE could not be applied. The analysis also notes that the higher rate under section 115BBE was regarded as operating prospectively from the relevant cut-off date, not on earlier concluded transactions. The surrendered amount was therefore taxable at the normal business rate rather than at the enhanced rate.</description>
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      <description>Surrendered income linked to stock and loose papers found during survey was treated as business income, because the record did not show any unexplained investment or income from a source outside the timber and plywood business. In the absence of the deeming fiction under section 69, the enhanced tax rate under section 115BBE could not be applied. The analysis also notes that the higher rate under section 115BBE was regarded as operating prospectively from the relevant cut-off date, not on earlier concluded transactions. The surrendered amount was therefore taxable at the normal business rate rather than at the enhanced rate.</description>
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