Dispute Over Tax Liability Enhancement Under IT Act Section 154; Ownership of Document u/s 69A Contested.

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....Rectification of mistake u/s 154 - enhancing the tax liability of the assessee u/s.115BBE - the impugned addition whether to be made u/s.69A is highly debatable in view of the submissions made by the assessee denying ownership of the document found in the course of search. When the taxability of the addition under a specific section is a point of contention / debatable, the tax levied on the said addition cannot be said to be not debatable. - AT....