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2023 (2) TMI 457
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....mon and inextricably interlinked or in fact interwoven and the facts and circumstances of other cases are exactly identical except the difference in the amount. The ld. DR did not raise any specific objection against taking that case as a lead case. Therefore, for the purpose of the present discussions, the case of ITA No. 155/JPR/2022 is taken as a lead case. 4. Based on the above arguments we have also observed that ground no. 1 & 2 in ITA NO. 154 /JPR/2022 and ground no. 2 & 3 in ITA No. 155/JPR/2022 were common and ground no. 1 in ITA 155/JPR/2022 more thus, except these on the two grounds for both the appeals grounds are similar, facts are similar, arguments were similar and therefore, were heard together the parties and are disposed the case by taking lead case facts, grounds and arguments from the folder in ITA No. 155/JPR/2022. 5. Before moving towards the facts of the case we would like to mention that the assessee has assailed this appeal in ITA No. 155/JPR/2022 before us on the following grounds; "1. In the facts and circumstances of the case and in law, ld. CIT(A) has erred in confirming the action of the ld. AO, in making additions of Rs. 4,55,639 toward....
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....nor Shaurya sethi & Kashvi during the year. 7. Accordingly notice u/s 142(1) of the Act was issued to the assessee on 14-09-2017 which was duly served. In response to notice issued u/s 142(1) the assessee furnished his return of income on 31-10-2017 declaring total Income of Rs. 1,77,10,650/-. It includes the surrendered income of Rs. 89.05 lacs which had been accepted by the assessee during the course of search. Penalty proceedings u/s 271AAB(1)(a) of the Income-tax Act, 1961 is being initiated for undisclosed income which was unearthed during the course of search. In the assessment proceeding the learned assessing officer has added a sum of Rs. 5,52,241/- being the unexplained jewellery in addition to what has been disclosed and offered. The relevant computation is reproduced herein below: "5.5 During the course of search, silver articles were also found. Considering the status of the assessee silver utensils and silver jewellery weighing 10 kg. is considered is explained. Therefore, the remaining silver jewellery i.e. 19,500 gram is treated as unexplained. Found Treated as explained Remained unexplained value Gold 2947 gram 1450 gram ....
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....he undisclosed investment in silver items of 27.03 Kgs is worked out at Rs.11,86,887/- as against Rs. 12,95,345/- worked out by the AO in respect of 29.5 Kgs., by applying the silver price at Rs.43,910/- as per valuation report and as also considered by the AO. Since the AO has himself considered 10,000 gms as explained, therefore the undisclosed investment in silver items is considered at 17,300 gms at Rs.7,59,643/- as against Rs.8,56,245/- for 19,500 gms considered, as unexplained, by the AO. (vi) Further, the contention of the appellant that the silver items were found to be explained during the course of search is not found to be acceptable in view of the fact that during the course of assessment nor during the current appellate proceedings, the appellant has been able to furnish any evidence regarding the source of acquisition of the aforesaid jewellery. In fact, considering the status of the appellant, the AO has already considered silver items worth 10 Kg as explained. Further since the aforesaid circular of CBDT is silent on the issue of silver jewellery/utensils and valuable stones and in absence of any evidence for acquisition of the aforesaid silver items and co....
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....e assessee is reiterated here in below:- "I. Assessee, an individual, for the relevant previous year, earned salary income from Nine Jewels Pvt. Ltd. Assessee also earned income from House Property, remuneration from partnership firm, short term capital gains etc. II. Search and seizure operation, under section 132(1), of the Income Tax Act, 1961 ("ITA") was carried out on 21.07.2016at the business and residential premises of the assessee.(AO Order Page 1) III. For the relevant previous year, assessee furnished his return of income on 31.10.2017, declaring total income of Rs. 1,77,10,650, out of which Rs. 89.50 lacs pertained to income surrendered during the course of search. Ground No. 2-3: Invoking provisions of Section 115BBE 1. ASSESSING OFFICER& COMMISSIONER OF INCOME TAX (APPEALS) 1.1. During the course of search assessee, on his own, offered Rs. 89,05,480 for tax, for the year at hand.Subsequently, in the assessment proceedings,ld. AO added Rs. 5,52,241, in the hands of the assessee, as unexplained jewellery (Silver Items). Ld. AO for the purpose of calculating tax, on the amount surrenderedby the assessee of Rs. 89,05,48....
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....passed by ld. AO. Ld. AO has not made addition of the income surrendered by the assessee, under Section 69 or any other similar section. A.3. Assessee came to know of the application of the higher rate of 77.25% under Section 115BBE only through the computation of income, annexed with the assessment order. Hence, there is no satisfaction recorded by the ld.AO for the purpose of invocation of Section 69 on the assessee. Under such circumstances invoking Section 115BBE is not justified. A.4. In this regard, reliance is placed on the below mention judicial pronouncements of the Hon'ble ITAT, Jaipur Bench, the relevant extracts of which are set out hereunder for the sake of ready reference:- A.4.1. Sudesh Kumar Gupta [2020] 117 taxmann.com 178 (Jaipur - Trib.) "...In the instant case, as we have noted above, the return of income so filed has been accepted by the Assessing officer without making any adjustment/variation to the income so offered by the assessee and the assessment has been completed u/s. 143(3) of the Act. Further, there is nothing on record which shows that the Assessing officer has called for any Explanation of the assessee regarding ....
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.... of the Assessing officer that during the assessment proceedings, the tax rate has been charged @ 30% on surrendered income u/s 115BBE of the Act is not factual correct as not borne out of assessment records and thus, the action of the Assessing officer in rectifying and increasing the rate of taxation from 30% to 60% and surcharge and cess on such undisclosed income doesn't come within the purview of section 154 of the Act...." [Emphasis Supplied] Thus, having not invoked Section 69 or not recorded any satisfaction in this regard, lower authorities was not justified in invoking the provisions of Section 115BBE. B. Where any non-income is converted by AO to income, as per Section 68 to 69B then only Section 115BBE can be made applicable. In the present case, assessee himself offered amount for taxation, which was even accepted as it is by the AO. B.1. Furthermore, provisions of Section 68 to Section 69D can only be invoked in cases where an assessee is unable to explain the source of a particular receipt, money, investment, expenditure, etc or part thereof to the satisfaction of the Assessing Officer. These provisions have no application in case where....
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....earch or at the time of making surrender, by the assessee, on 21.07.2016, the amended provisions were not in place. The amendment to section 115BBE, being onerous on the assessee, should not be given a retroactive effect. C.1. The provisions of Section 115BBE were inserted in the ITA by Finance Act, 2012, with effect from 1.04.2013. Section 115BBE taxed the unexplained credits, money, investment, expenditure, etc., which were deemed as income under Section 68, Section 69, Section 69A, Section 69B, Section 69C or Section 69D, at the rate of 30% (plus surcharge and cess), without allowing any deduction for any expenditure or allowance. C.2. Thereafter, the provisions of sub-section (1) of Section 115BBE were substituted by Taxation Laws (Second Amendment) Act, 2016, w.e.f 1.04.2017 i.e. AY 2017-18 ("Amendment -115BBE"). Although, Taxation Laws (Second Amendment) Act, 2016 received the assent of the President of India only on 15.12.2016.Search on the assessee was carried out on 21.07.2016. C.3. Chronology of various events, as discussed hereinbefore, is as under :- Particulars Date 115BBE Introduced for the first time in the Income Tax Act. Rate of ....
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....ot to be intended to have a retrospective operation. The idea behind the rule is that a current law should govern current activities, which is based on the principle of law known as lex prospicit non respicit : law looks forward not backward. Thus, legislation which modify accrued rights, or which imposes obligation or impose new duties or attach a new disability have to be treated as prospective, unless the legislation is for purpose of supplying an obvious omission in a former legislation or to explain a former legislation. C.8.1. Hon'bleApex Court, in the said case was considering the time period, (within the relevant previous year) of applicability of the new inserted proviso to Section 113 levying surcharge over and above the tax rate of 30% in case of block assessments; C.8.2. Proviso was introduced vide Finance Act, 2002, with effect from 1.06.2003. Thus, the law stoodenacted as on 1.04.2003 and, accordingly, as per normal principles should have applied on all searches carried out during Financial Year 2002-03 (AY 2003-04). C.8.3. Hon'ble Apex Court was pleased to hold that amendment would apply prospectively and would be applicable on searches con....
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....court, it is the actual substance of the amendment that determines its ultimate operation and not the bare language in which such amendment is couched. A clarificatory amendment presumes the existence of a provision the language of which is obscure, ambiguous, may havemade an obvious omission, or is capable of more than one meaning. In such case, a subsequent provision dealing with the same subject may throw light upon it. Yet, it is not every time that the legislature characterizes an amendment as retrospective that the Court will give such effect to it. This is not in derogation of the express words of the law in question, (which as a matter of course must be the first to be given effect to), but because the law which was intended to be given retrospective effect to as a clarificatory amendment, is in its true nature one that expands the scope of the section it seeks to clarify, and resultantly introduces new principles, upon which liabilities might arise. Such amendments though framed as clarificatory, are in fact transformative substantive amendments, and incapable of being given retrospective effect. An important question, which arises in this context, is whether a "clarificat....
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....s submitted that when the assessee made surrender of his income, during the course of search, on 21.07.2016, the amended provisions of section 115BBE were not in existence. C.14. Where an amendment, as under 92B, although was introduced having a retrospective effect, was held, by the courts, to have a prospective effect, by the same analogy, an amendment to Section 115BBE, putting additional burden on the assessee, introduced on 15.12.2016, w.e.f 01.04.2017(A.Y 2017-18), should not be made applicable on any act committed between 01.04.2016 to 14.12.2016. C.15. The amendment to Section 115BBE is penal in nature, which aims to penalize the assessee, if additions referred to in Section 68 to 69A are made. Penal statutes which create offences or which have the effect of increasing penalties for existing offences will only be prospective by reason of the constitutional restriction imposed by ARTICLE 20 of the CONSTITUTION OF INDIA. Therefore, if an Act creates a new offence, it will bring into its fold only those offenders who commit all ingredients of the office after the Act comes into operations. This rule of construction against retroactivity of penal laws is not r....
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....ch arrangement of affairs should not be dislodged by retrospective application of law. C.17.2. The principle of law known as lex prospicit non prospicit (law looks forward not backward), is a well known and accepted principle. The retrospective legislation is contrary to general principle for legislation by which the conduct of mankind is to be regulated when introduced for the first time to deal with future acts ought not to change the character of past transactions carried out in the faith of the then existing law. C.17.3. Thus, the principle against retrospectivity is the principle of 'fairplay' and unless there is a clear and unambiguous intendment for retrospective effect to the legislation which affects accrued rights or imposes obligations or castes new duties or attaches a new disability is to be treated as prospective Thus, act of the assessee, of surrendering certain amount, u/s 132(4), on 21.07.2016, cannot be penalized with a higher rate of tax, of 77.25% as against 30%, by way of an amendment brought about in the Statute Book subsequently. D. Intention of the amendment to Section 115BBE was to cover cases of concealment of in....
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.... his Return of Income and has not tried to "conceal" any particulars of income. This even finds force from the fact that no further additions were made by the ld. AO during the course of assessment proceedings. D.6. Having made the disclosure, the assessee clearly doesn't fall in the category, the prevention of which, was the reason for which said amendment was made u/s 115BBE. D.7. Hon'ble Calcutta High Court in the case of Pilani Investments and Inductries Corpn. Ltd. [2016] 383 ITR 635/238 Taxman 384/67 Taxman.com 60 held that disclosure and concealment cannot coexist. 2.2. Ld. CIT(A), at Page 12, of her order has stated that if any income is surrendered by the assessee, then it would still be in the nature of income under Section 68 to 69D and thus the provisions of Section 115BBE would be applicable. It is submitted that for applicability of Section 68 to 69D, there is a clear requirement of satisfaction having been recorded by the Assessing Officer. Thus, for invocation of Section 68 to 69D satisfaction has to be recorded by the Assessing Officer and in his opinion the said income should be added under such sections. However, in the present case, no....
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....e course of assessment proceedings. GROUND NO. 1: ADDITION OF RS. 4,55,639 TOWARDS UNEXPLAINED INVESTMENT IN JEWELLERY 1. BRIEF FACTS 1.1. During the course of search on the assessee, jewellery, consisting of gold items, precious stones and silver utensils/articles, of the value of Rs. 97,88,630 were found from the Residential premises of the assessee, along with the lockers maintained by him (AO Order page 5). 1.2. Out of such total value of jewellery, jewellery worth Rs. 41,83,150 was found to be explained, during the course of search proceedings itself (AO Order page 7). In such jewellery, found to be explained, entire Silver utensils/articles, of 27.30 kgs were included (AO Order page 7). 1.3. The remaining amount of jewellery, consisting of Gold items and Precious Stones, of Rs. 56,05,480 (Rs. 97,88,630- Rs. 41,83,150), was found to be unexplained, during the course of search (AO Order page 8). Such amount was thus surrendered by the assessee during search itself. 1.4. Silver Items were found to be explained, during the course of search itself by the Departmental officers on the field. The same is evident from the SEIZURE M....
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....3. Furthermore, following submissions made before the lower authorites have been totally ignored:- 3.3.i CBDT Instruction No. 1916 Dated 11.05.1994, clearly specified as under:- "...(iii) The authorized officer may having regard to the status of the family and the customs and practices of the community to which the family belongs and other circumstances of the case, decide to exclude a larger quantity of jewellery and ornaments from seizure. This should be reported to the Director of Income-tax/Commissioner authorizing the search all the time of furnishing the search report..." 3.3.ii Accordingly, as per CBDT, if having regard to the status of the family and the customs and practices of the community to which the family belongs and considering other circumstances a higher quantity of jewellery and ornaments can be considered to have been explained. 3.3.iii Income Tax Authorities are not necessarily required to just consider the limits as prescribed in the CBDT circular to be explained. Even similar ratio has been laid down by Hon'ble Rajasthan High Court in the case of Satya Narain Patni [2014] 46 taxmann.com 440in which the Hon'ble Court has acc....
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....during the course of the fiscal year, tax rates for which stand already clarified at the beginning of the year per the relevant Finance Act (FA, 2016). The said words 'at once' would loose significance if the provisions of the Act are to, as stated by the ld. CIT(A), be read as effective 01/04/2017, implying AY 2018-19. The same, for substantive amendments, as in the instant case, represents the first day of the assessment year, i.e., AY 2017- 18,which explains the assessee's grievance of it being thus effective for fy 2016-17 or,w.e.f. 01/4/2016. Enacting it mid-year and, further, making it applicable 'at once', becomes meaningless if the same is to take effect retrospectively, or is made effective from a later date (01/4/2017), which could in that case be by Finance Act, 2017. True, the amendment, where so read, does gives rise to a peculiar situation inasmuch as two tax rates would obtain for the current year, i.e., one from 01/04/2016 to 14/12/2016,and another from 15/12/2016 to 31/03/2017, but, then, that is no reason to read retrospectively where the applicable date is clear and, further, there is nothing to suggest retrospectively. Further, extraordinary ....
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....rovision section 115BBE is penal in nature it will not apply retrospectively because the increase in rate is after the disclosure made consequent upon the search and that time effective tax rate was 30 % whereas ld. AO has wrongly applied it with retrospective @ 60 % for which the assent to increase the rate received the president assent on 15.12.2016 just after the demonetization on 08.11.2016. This fact is further fortified that the ld. AO has invoked the provision of section 271AAB(1)(a) for the amount disclosed during the search proceeding and no separate notice of his intention to invoke the provision of section 115BBE was given to the assessee and thus the invoking of the provision of section 115BBE is against the principles of nature justice. The assessment order is silent on the invocation of provision of section 115BBE qua the provision of section 68,69,69A,69B,69C or 69D. 12. The ld. DR is heard who has relied on the findings of the lower authorities as regards the addition sustained. As regards the charge of tax u/s. 115BBE he has vehemently argued that provision section 4 being the charging section does not support the contentions of the assessee so raised. Therefore....
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....the Taxation Laws (Second Amendment) Act, 2016, by which the tax rate of 60% was inserted, have not been discussed in the said order. Unfortunately the aforesaid order also does not mention charging section 4 of the Act. which is very relevant to decide the issue. Therefore, with due respect to the Hon'ble Co-ordinate Bench, the said order is per-incuriam and need not be followed by the Hon'ble Jaipur Bench. This will be clear from the following discussion: 1. As per the provisions of section 4 of the Act, where any Central Act enacts that income-tax shall be charged for any assessment year at any rate or rates. income tax at that rate or those rates shall be charged for that year in accordance with, and subject to the provisions in respect of the total income of the previous year of every person. It is clear from the charging provision that rate of tax is to be determined for whole of the assessment year as per the relevant Central Act. There is no concept of charging of tax at a particular rate for one part of the year and other rate for the other part of the year, unless provided in the Act itself. 2. The Taxation Law (Second Amendment) Act, 20....
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....various judgements but these judgements are not applicable in the facts of the present case. These judgements deal with the issue of retrospective taxation. The issue in hand is not with regard to retrospective taxation, because Act has been amended in the same year. The only difference is that instead of prior to 1 April, the Act has been amended after first April of the relevant previous year, although amendment has been made before 1st April, 2017 which is the commencement date of the relevant assessment year. The tax liability will arise after the end of the previous year and on 1st day of the assessment year because return of income is filed after completion of the previous year. The above issue is dealt with in the case of Bhagvathy Tea Estates Ltd v State of Kerala by the Hon'ble Kerala High Court reported in 50 Taxman 180 (Copy enclosed). The case was related to Kerala Plantation Tax Act, 1960, but legal principles are applicable in the present case also because the contentious issue was similar to the present one. Plantation tax was imposed in the state of Kerala under the Plantation Tax Act and the rates of tax were indicated in the Schedule. Those rates were....
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....ate of Kerala [1960] KLT 14S considered the applicability of a taxing enactment which came into force on 1-9-1957, in relation to the assessment year 1957-58 (1-4-1957 to 31-3-1958). The contention was that the Act was inapplicable to transactions prior to 1-9-1957. The contention was rejected. The crux of the decision contained in that, brief but brilliant, judgment is contained in the words: "In other words, the year is the unit and because a few months of the year 1957-58 were anterior to the date on which the Act came into force, it cannot be said that the transactions during those months are exempt from the surcharge leviable under the Act. This does not mean that the Act is retroactive in character. A statute is not retrospective simply because a part of the requisites for its action is drawn from a time antecedent to its passing." (Craies on Statute Law, Fifth end., p. 357). " It is clear from the above discussion that tax rate applicable in the assessment year is the relevant rate to be applied irrespective of the fact that whether amendment was made in the beginning of the year or in the middle of the year. 5. There is no gainsaying that equitabl....
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.... therefore the differential amount of Rs. 4,55,639/-(Rs. 60,61,119 - Rs. 56,05,480) is treated as unexplained. (vii) Therefore the addition to the extent of Rs. 4,55,639/- is sustained instead of Rs. 5,52,241/- made by the assessing officer and the balance of Rs. 96,602/- (Rs. 5,52,241/- minus Rs. 4,55,639/-) is deleted. Accordingly, the Ground No. 1 stands partly allowed." 13.2 In the proceeding before us the ld. AR of the assessee has contended the search team has considered the explanation granted by the assessee and there is no disclosure or seizure of the silver items itself considered that the search team has considered the explanation of the assessee and those itesm were considered as explained considering the social status and culture of the family to have such items for their use. The relevant questions and answer made at the search prove the contentions. The relevant questions countered to the assessee is reproduced for the sake of clarity: 13.3 On this issue ld. DR only relied upon the fact that relief granted by the ld. AO up to 10 kg is sufficient and no further relief should be granted beyond what has been given by the lower authority. 13.4 Based on ....
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.... Penalty where search has been initiated. 271AAB. (1) The Assessing Officer 20-21[or the Commissioner (Appeals)] may, notwithstanding anything contained in any other provisions of this Act, direct that, in a case where search has been initiated under section 132 on or after the 1st day of July, 2012 but before the date on which the Taxation Laws (Second Amendment) Bill, 2016 receives the assent of the President, the assessee shall pay by way of penalty, in addition to tax, if any, payable by him,- (a) a sum computed at the rate of ten per cent of the undisclosed income of the specified previous year, if such assessee- (i) in the course of the search, in a statement under sub-section (4) of section 132, admits the undisclosed income and specifies the manner in which such income has been derived; (ii) substantiates the manner in which the undisclosed income was derived; and (iii) on or before the specified date- (A) pays the tax, together with interest, if any, in respect of the undisclosed income; and (B) furnishes the return of income for the specified previous year declaring such undisclosed income therein; (....
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.... of the undisclosed income in Pradhan Mantri Garib Kalyan Deposit Scheme, 2016. The deposits are interest free and have a lock-in period of four years. (iii) The income declared under the Scheme shall not be included in the total income of the declarant under the Income-tax Act for any assessment year. (iv) The declarations made under the Scheme shall not be admissible as evidence under any Act (eg. Central Excise Act, Wealth-tax Act, Companies Act etc.). However, no immunity will be available under Criminal Acts mentioned in section 199-0 of the Scheme. Non declaration of undisclosed cash or deposit in accounts under the Scheme will render such undisclosed liable to tax, surcharge and cess totaling to 77.25% of such income, if declared in the return of income. In case the same is not shown in the return of income a further penalty @10% of tax shall also be levied followed by prosecution. It may be noted that the provisions for levy of penalty for misreporting of income @200% of tax payable under section 270A of the Income-tax Act have not been amended and shall continue to apply with respect to cases falling under the said section. The Taxation ....
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....ature justice as no such issue is raised, discussed and confronted with the assessee. Thus, we direct the assessing officer to strict the calculation of tax in accordance with the provision of law as discussed here in above and give the relief in tax calculation accordingly. In terms of these observation, we allow the ground no 2 & 3 raised by the assessee. 15. The fact of the case in ITA No. 154/JPR/2022 are similar to the case in ITA No. 155/JP/2022 and we have heard both the parties and persuaded the materials available on record. The bench has noticed that the issues raised by the assessee in this appeal in ITA No. 154/JPR/2022 are equally similar on set of facts and grounds. Therefore, it is not imperative to repeat the facts and various grounds raised by both the parties. Hence, the bench feels that the decision taken by us in ITA No. 155/JP/2022 for the Assessment Year 2017-18 shall apply mutatis mutandis in the case of Shri Rajiv Nogotiya in ITA No. 154/JPR/2022 for the Assessment Year 2017-18. In the result, both the appeals of the assessee are allowed. Order pronounced in the open court on 08/02/2023 ============= Document 1 “पà¥à¤°à¤¶à....
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....वाई गई Registered Govt. Valuer दà¥à¤µà¤¾à¤°à¤¾ हमारे घर à¤à¤µà¤‚ लॉकर से मिले Gold Jewellery with diamonds / stones studds à¤à¤µà¤‚ Silver Jewellery / Utensils का मूलà¥à¤¯à¤¾à¤‚कन से मैं पूरà¥à¤£à¤¤à¤ƒ सहमत हूà¤à¥¤ यह उपरोकà¥à¤¤ Jewellery मेरे परिवार में मेरी माता, पतà¥à¤¨à¥€, बचà¥à¤šà¥‡ à¤à¤µà¤‚ मेरी खà¥à¤¦ की Jewellery है जो विà¤à¤¿à¤¨à¥à¤¨ समारोहों में à¤à¤µà¤‚ कà¥à¤› मेरी savings से purchase की हà¥à¤ˆ Jewellery हैà¤....
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....¿à¤¯à¥‡ गये निवेश को अपनी अघोषित आय ( unexplained income) मानते हà¥à¤ चालू वितà¥à¤¤ वरà¥à¤· में आयकर के लिठसमरà¥à¤ªà¤¿à¤¤ करता हूठमैं इस मामले में आगे सà¥à¤ªà¤·à¥à¤Ÿà¥€à¤•à¤°à¤£ देना चाहूà¤à¤—ा कि उपरोकà¥à¤¤ रूपये 5605000/- का निवेश मैनें अपनी सà¥à¤µà¤¯à¤‚ की चालू वितà¥à¤¤ वरà¥à¤· की अघोषित आय मानते हà¥à¤ ....
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.... 15th December, 2016, and is hereby published for general information:- THE TAXATION LAWS (SECOND AMENDMENT) ACT, 2016 (No. 48 OF 2016) [15th December, 2016.] An Act further to amend the Income-tax Act, 1961 and the Finance Act, 2016. BE it enacted by Parliament in the Sixty-seventh Year of the Republic of India as follows:- CHAPTER I PRELIMINARY 1. (1) This Act may be called the Taxation Laws (Second Amendment) Act, 2016. (2) Save as otherwise provided in this Act, it shall come into force at once. CHAPTER II INCOME-TAX 2. In the Income-tax Act, 1961 (hereinafter referred to as the Income-tax Act), in section 115BBE, for sub-section (1), the following sub-section shall be substituted with effect from the 1st day of April, 2017, namely:- Short title and commencement. Amendment of section 115BBE. "(1) Where the total income of an assessee, (a) includes any income referred to in section 68, section 69, section 69A, section 69B, section 69C or section 69D and reflected in the return of income furnished under section 139; or THE GAZETTE OF INDIA EXTRAORDINARY [PART II- Amendment of section 271AAB. ....