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2008 (9) TMI 114 - DELHI HIGH COURTBlock assessment – whether surcharge could be levied in the case of a search carried out prior to June 1, 2002 i.e. prior to insertion of proviso to section 113 - Tribunal concluded that issue with regard to the levy of surcharge was debatable when the AO passed his order on June 11, 2003, u/s 154, therefore the rectification proceedings were not in order – held that issue was debatable one and hence provisions of s. 154 couldn’t be invoked – no reason to interfere with the findings of tribunal
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