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    <title>2026 (6) TMI 36 - ITAT JABALPUR</title>
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    <description>The enhanced rate under section 115BBE was held inapplicable to surrendered income for assessment year 2017-18 because the amendment was treated as prospective and not retrospective in the absence of clear legislative intent. The Tribunal further held that rectification under section 154 could not be used to recast an assessment on a debatable point of law, since the original assessment had already applied the prevailing rate. As a result, the tax adjustment was deleted and the assessee&#039;s appeal was allowed.</description>
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      <description>The enhanced rate under section 115BBE was held inapplicable to surrendered income for assessment year 2017-18 because the amendment was treated as prospective and not retrospective in the absence of clear legislative intent. The Tribunal further held that rectification under section 154 could not be used to recast an assessment on a debatable point of law, since the original assessment had already applied the prevailing rate. As a result, the tax adjustment was deleted and the assessee&#039;s appeal was allowed.</description>
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