Section 115BBE addition unsustainable for Search conducted prior to 01.04.2017

DCIT Vs Punjab Retail Pvt. Ltd (ITAT Indore) Held that search was carried out before the amendment, the addition ought to have been made in terms of the prevailing provision. Therefore, the addition made by the AO invoking Section 115BBE provision of which came into force only on 01.04.2017 is not sustainable. Facts- The assessee company on 07.11.2017 declared the total income at Rs. 28,56,20,940/- including additional income surrendered of Rs. 10,14,95,122/- and Rs. 1,20,02,793/- during the course of search and survey proceeding respectively. The AO calculated the difference in the valuation ...