TMI Blog2023 (2) TMI 33X X X X Extracts X X X X X X X X Extracts X X X X ..... nd 69D shall attract tax rate at 60% along with the application surcharge penalty - petitioner herein is saddled with the huge tax liability for the assessment year 2017-18 - action of the AO of issuing the notice for recovery of demand raised pursuant to the assessment under Section 143(3) of the Act. Assessee relied on the decision of Pragati Cooperative Bank Ltd [ 2005 (6) TMI 26 - GUJARAT H ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... constitutional validity of Section 115 BBE of the Income Tax Act, 1961 as substituted by the Taxation Laws (Second Amendment) Act, 2016 w.e.f. 01.04.2017 pursuant to which the income determined by the Assessing Officer under Sections 68, 69, 69A, 69B, 69C and 69D of the Income Tax Act, 1961 shall attract tax rate at 60% along with the application surcharge penalty. The petitioner herein is saddle ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ther writ, order or direction quashing and setting aside the recovery notice dated 15.12.2022 (Annexure-B); (d) Pending final hearing and admission of the matter, pass an order restraining the Respondents from enforcing demand for A.Y.2017-18 and be further pleased to stay the impugned recovery notice dated 15.12.2022 (Annexure-B); (e) alternatively, direct the first appellate authorit ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... YC documents as the petitioner is the Bank and all those documents of the customers, who deposited their cash in their account during the demonetization period, have been duly submitted and yet, the officer in complete disregard to these details has added wrongly this amount in the income of Bank and finalized the assessment. The petitioner has also filed appeal before the CIT (Appeals), which is ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
