Deemed nullity of income declaration permits addition as unexplained investment, but tax on that addition computed at 30% not 60%.

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....Declaration under the Income Declaration Scheme was held void for failure to pay tax, surcharge and penalty within the statutory time, rendering the declaration deemed never made and making the undeclared amount chargeable in the previous year (FY 2016-17) under the deeming provision; because the assessee failed to satisfactorily explain the source, the AO's addition as unexplained investment was upheld. The amended higher tax rate was held non-retrospective, so tax on the addition must be computed at the earlier 30% rate rather than the later 60% rate, resulting in a partly allowed outcome.....