TaxTMI 
TaxTMI 
2026 (1) TMI 63
X X X X Extracts X X X X
X X X X Extracts X X X X
.... Act of ld Pr. CIT, Ranchi dated 30.3.2022 in DIN & Order No.ITBA/Rev/F/Rev 5/2021-22/10421168150(1) for the assessment year 2017-18. 3. In this case, the appeals have been filed on 6.5.2022. The appeals have been posted on multiple occasions nearly 21 times. None appeared on behalf of the assessee. The notice had also been sent through Regd. post, email and also served through Department. Still, the assessees have not represented in these cases. However, the assessee has filed written submissions, which read as follows: Further submissions for I. T. A. No. - 19/RAN/2022 in the matter of Dr. Satish Kumar Midha for the Assessment Year - 2017-18 bearing PAN No. - ABGPM4998Q Submissions To, The Honourable Me....
X X X X Extracts X X X X
X X X X Extracts X X X X
....losed income found during survey as assessee's business income, Commissioner erred in initiating revision proceeding on basis that disclosed amount must be taxed under section 115BBE rather than being shown as business income". This covers the issue. The physical copy of the impounded documents are produced before your honour. Kindly let us know which documents your honour wants to peruse. The originals are still lying with the Ld. Assessing Officer. Without prejudice to above :- As per Section 158BA(7) states that as follows :- "The total income relating to the block period shall be charged to tax, at the rate specified in section 113, as income of the block period irrespective of t....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ply to the assessment year 2017-18. When an amendment is made effective from 1st April of a particular year that relates to the said accounting year. The assessment year in this case would be next year. Thus, the assessment year would be for an amendment which has taken effect from 1.4.2017 will be assessment year 2018-19. Ld Pr. CIT has also referred to the decision of the Hon'ble Supreme Court in the case of Reliance Jute Industries, 120 ITR 912 (SC), wherein, the Hon'ble Supreme Court has held that the law as on the beginning of the year is the law that has to be applied for the assessment year. The survey in the impugned case appeals took place on 14.9.2016, the Gazette Notification in respect of Section 115 BBE was on 15.12.2016. The e....
X X X X Extracts X X X X
X X X X Extracts X X X X
....2017-2018. Further the amendment to section 115BBE is directly related to demonetization which would be evident from objects and reasons for such amendment. In order to consider the same, the objects and reasons of Taxation Laws (Second Amendment) Bill 2016 is extracted hereunder: ....... ...... 17. In the aforesaid objects and reasons nowhere it is stated that due to "demonetization" the unaccounted money ought to be charged 60% rate of tax. It only states that step had been taken to curb black money by withdrawing Specified Bank Notes of denomination of Rs. 500 and Rs. 1000. And also states the people may find illegal ways of converting their black money into black again, hence as per experts advice heavy penalt....