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Cit, Ernakulam vs P.K. Noorjahan (Smt) on 15 January, 1997

"T. The Petitioner further submits that the invocation of section 115BBE in the present case is grossly unfair. The Petitioner seeks the indulgence of our Hon'ble Court in determining the Constitutional vires of section 115BBE of the Act in as much as the same is violative of Article 14, Article 19 as also the fundamental Economic Justice guaranteed in the Constitution. In the humble submission of the Petitioner the section is prone to abuse based on a subjective exercise of discretion whereby it will completely depend on the subjective opinion and subjective satisfaction of the Assessing Officer as to whether in a particular case sections 68 to 69D should be invoked or not. Admittedly, the very sections 68 to 69D are discretionary in nature and not mandatory [Ref. CIT v/s P.K. Noorjahan - (1999) 237 ITR 670 (SC)] and because of that they are prone to the vice of perversity in exercise thereof. This may lead to a situation where similarly placed assessees may be subjected to differential treatment under the Act based on the discretion of the Assessing officer. The very section 115BBE is prone to mischief. It can be manifested by way of a simple illustration. Suppose two different assesses in the very same business earning the very same nature of income are assessed before the same Assessing Officer wherein income from business earned in cash is disclosed by both the Assessees. The said income is taxable u/s 28 of the Act. It needs to be mentioned that even incomes to which sections 68 to 69D apply have to be classified under one of the specific heads as per section 14. Now, if the Assessing Officer chooses to apply section 68 to business income earned in cash in the case of one assessee and chooses not to do so in the case of another assessee, it will lead to absolutely unfair levy of tax because the Assessee in whose case the said section 68 is applied would end up being charged with more than double the tax liability [since from AY 2017-18 tax u/s 115BBE is 60% plus 25% surcharge and further penalty and interest]. In an even worse situation like the present one, the Assessing Officer could simply invoke section 68 simply to safeguard his invalid action and consequently subject the Assessee to the rigours of section 115BBE simply because the exercise of discretion was inappropriate. It is with utmost respect submitted that the Act, does not provide a safeguard against a biased mind. It is for this reason, the Petitioner seeks indulgence of this Hon'ble Court in redressing the grievance of the injustice caused by section 115BBE of the Act, just as has happened in the present case.
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