Section 115BBE classification requires a valid deeming-provision basis before special taxation, while the enhanced rate's temporal application remains disputed.

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....Section 115BBE applies only where income is validly assessable under sections 68 to 69D; a disclosure, surrender, cash deposit or addition alone does not establish that prerequisite. Qualifying income is subject to the special rate and cannot be reduced by expenditure, allowances or loss set-off. The 2016 substitution raising the principal rate from 30% to 60% expressly operates from 1 April 2017. Under the prospective approach, financial year 2016-17 remains taxable at 30%, while a contrary approach applies the revised rate to assessments for the following assessment year. Classification under a deeming provision must therefore precede rate application. Penalty under section 271AAC depends on a valid section 115BBE determination and satisfaction of its statutory conditions.....