ITAT Quashes Rectification U/S 154: Debatable Issue Cannot Trigger Section 115BBE Special Tax

9th Street Architects Vs DCIT (ITAT Ahmedabad) Survey Disclosure Already Taxed as Business Income – AO Cannot Invoke 69A & 115BBE Through 154 Rectification- Debatable Issue Beyond Scope of 154 -Rectification Cannot Become Reassessment A survey u/s 133A was conducted in the case of Assessee-firm engaged in architectural consultancy. During survey, Assessee admitted that ₹1,50,00,000 was not recorded in the regular books. Assessee explained that these receipts were professional consultancy fees from its regular business, duly offered to tax as business income in the return, & the ass...