2026 (5) TMI 1398

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....Sr. DR (VC) ORDER PER M. BALAGANESH, A. M.: 1. The appeal in ITA No.9136/Del/2025 for AY 2017-18, arises out of the order of the Commissioner of Income Tax (Appeals)-3, Gurgaon [hereinafter referred to as 'ld. CIT(A)', in short] dated 23.10.2025 against the order of assessment passed u/s 143(3) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act') dated 30.12.2019 by the Asse....

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....tion 115BBE of the Act for the said surrendered income. This action of the Learned AO was upheld by the Learned CITA. We find that the Hon'ble Madras High Court in the case of SMILE Microfinance Limited vs ACIT in WP (MD) No. 2078 of 2020 and WMP (MD) No. 1742 of 2020 dated 19-11-2024 had held that the provisions of section 115BBE of the Act which enhanced the rate of tax could be made applicable ....