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counsel appearing for the respondents, on instructions, draws our attention to Section 115BAA(5) of the Income Tax Act, 1961["Act"] to contend ... submission bearing in mind the plain language in which sub-section (5) of Section 115BAA of the Act stands couched as also Rule 21AE

that the respondents were bound to follow the procedure contemplated under Section 115BAA of the Taxation Laws (Amendment) Act, 2019. 2. In view