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“maximum marginal rate”

Chapter I - PreliminarySection 2 - DefinitionsSection 2(29C) / ITR-6 Schedule 115TD587 judgments

The decision most relied on for maximum marginal rate is 1. Father Mullers Charitable Institutions 363 IT 230 (Kar.) 2. DIT(E) v. Sheth Mafatlal Gagalbhai Foundation Trust (249 ITR 533), cited in 108 judgments on BharatTax.

Leading authorities on maximum marginal rate

1. Father Mullers Charitable Institutions 363 IT 230 (Kar.) 2. DIT(E) v. Sheth Mafatlal Gagalbhai Foundation Trust
249 ITR 533 · 2001 · High Court
108
citing judgments

Income of a trust that is taxable at the maximum marginal rate should be taxed accordingly, while other income is eligible for exemption under Section 11 of the Income-tax Act.

DIT v. Bharat Diamond Bourse
259 ITR 280 · 2003 · Supreme Court
86
citing judgments

Violation of investment mandates under Section 13(1)(d) of the Income Tax Act, 1961, for a charitable trust results in the complete denial of exemption under Section 11 of the Act.

Trust (249 ITR 533) (Bom.) 3. CIT vs. Red Rose School (163 Taxman 19 (All.) 4. DIT(E) v. Alarippu (
172 ITR 698 · 1988 · High Court
61
citing judgments

Income received by a trust from sources like extra fees can be taxed at the maximum marginal rate, while other income remains eligible for exemption under Section 11 of the Income Tax Act.

CWT v. Trustees of H.E.H. Nizam’s
108 ITR 555 · 1977 · Supreme Court
46
citing judgments

Where the shares of beneficiaries in a trust are determinate, trustees must be assessed separately for each beneficiary's share, treating each beneficiary as an individual. The income is then taxed at the marginal rate applicable to individuals, not at the maximum rate for an association of persons.

CIT v. Working Women’s Forum
365 ITR 353 · 2014 · High Court
34
citing judgments

When an exemption is denied under Section 13(1)(c) or (d), the denial of exemption applies only to the portion of income that violates these provisions, not the entire income.

CIT v. V.S. Dempo & Co. Pvt. Ltd.
336 ITR 209 · 2011 · High Court
27
citing judgments

Disallowance under Section 40A(2)(b) is not maintainable when both the payer and payee are assessed at the maximum marginal rate, as it results in a revenue-neutral situation.

Kar.) 2. DIT(E) vs. Sheth Mafatlal Gagalbhai Foundation Trust (249 ITR 533) (Bom.) 3. CIT v. Red Rose School (
224 ITR 358 · High Court
22
citing judgments

Income received by a trust that is considered 'extra fees' is taxable at the maximum marginal rate, while other income of the trust is eligible for exemption under Section 11.

Araadhya Jain Trust v. ITO
173 Taxmann.com 343 · 2025 · ITAT
22
citing judgments

The definition of maximum marginal rate under section 2(29C) can be interpreted to determine the applicable surcharge rates, particularly for income including dividends, as per the First Schedule to the Finance Act. This affects how surcharge is calculated on taxable income.

Judgments citing maximum marginal rate

Pawai Trust, New Delhi vs. Deputy Commissioner of Income Tax, New Delhi

In the result appeal filed by the assessee is allowed

ITA 5106/DEL/2025[2021-22]Status: DisposedITAT Delhi06 Feb 2026AY 2021-22

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhanpawai Trust , Vs. Dcit B-60-61 C/O Bajaj Auto Ltd. Cirlce 49(1) Naraina Industrial Area Phase Ii Delhi New Delhi (Pan: Aaatp0445J)

For Appellant: Ms. Vasanti Ben Patel, Adv &For Respondent: Sh. Ankush Kalra, Sr DR
Section 11Section 143(1)Section 234CSection 243CSection 243c

processed u/s 143(1) of the Income Tax Act (in short “Act”) and they proceeded to determine the taxable income and adopted maximum marginal rate (MMR), instead of applying normal slab rates applicable in the case of the trust. In that process the interest determined u/s 243C ... been raise whether the provisions of section 167 A of the Income-tax Act which provide for charging of tax at the maximum marginal rate on the total income of an association of persons where the individual shares of members in the income of such association are indeterminate or unknown

DCIT(Exemptions)-1(1), Mumbai vs. Aditya Birla Foundation, Mumbai

The appeals of the Revenue are dismissed

ITA 7609/MUM/2025[2017-18]Status: DisposedITAT Mumbai05 Feb 2026AY 2017-18

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokar & Dcit(Exemption)-1(1), Aditya Birla 6Th Floor, Mtnl Foundation, Building, Pedder Road, Vs. C-1, Aditya Birla Cumballa Hills, Centre, S. K. Mumbai-400 026 Ahiremarg, Worli, Mumbai-400 030 Pan/Gir No. Aaata0382P (Applicant) (Respondent) Assessee By Shri Ronak Doshi & Shri Surajsingh Devda, Ld. Ars Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 28.01.2026 Date Of Pronouncement 05.02.2026

Section 11Section 12ASection 13Section 13(1)(c)Section 13(2)(a)Section 13(3)Section 250

rent estimated by the District Valuation Officer in place of the actual rent received, and taxed the income of the assessee at the maximum marginal rate under section 164(2). The Assessing Officer further recorded that the activities of the trust were not genuine and characterised the leasing arrangement

DCIT(Exemptions)-1(1), Mumbai vs. Aditya Birla Foundation, Mumbai

The appeals of the Revenue are dismissed

ITA 7608/MUM/2025[2016-17]Status: DisposedITAT Mumbai05 Feb 2026AY 2016-17

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokar & Dcit(Exemption)-1(1), Aditya Birla 6Th Floor, Mtnl Foundation, Building, Pedder Road, Vs. C-1, Aditya Birla Cumballa Hills, Centre, S. K. Mumbai-400 026 Ahiremarg, Worli, Mumbai-400 030 Pan/Gir No. Aaata0382P (Applicant) (Respondent) Assessee By Shri Ronak Doshi & Shri Surajsingh Devda, Ld. Ars Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 28.01.2026 Date Of Pronouncement 05.02.2026

Section 11Section 12ASection 13Section 13(1)(c)Section 13(2)(a)Section 13(3)Section 250

rent estimated by the District Valuation Officer in place of the actual rent received, and taxed the income of the assessee at the maximum marginal rate under section 164(2). The Assessing Officer further recorded that the activities of the trust were not genuine and characterised the leasing arrangement

Shashi Krishna Educational Avam Welfare Society, Patna vs. AO, Patna

ITA 428/PAT/2025[2018-19]Status: DisposedITAT Patna29 Jan 2026AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 11Section 12ASection 12A(1)(b)Section 143(1)Section 154Section 250

well as capital account). Since exemption u/s 11 was denied, AO, CPC taxed the entire receipts of Rs.1,27,76,341/- at maximum marginal rate. On the other hand, the appellant claimed that even if exemption u/s 11 is denied, only the income over expenditure should be taxed

Vihar Trust, New Delhi vs. Deputy Commissioner of Income Tax, New Delhi

In the result, captioned appeals of the assessee in ITA Nos

ITA 4374/DEL/2025[2023-24]Status: DisposedITAT Delhi29 Jan 2026AY 2023-24

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 11Section 12ASection 143(1)Section 167BSection 250

applicable to the individual however, the while processing the return of income for all the three years, CPC has charged the tax at Maximum Marginal Rate (“MMR”) and levy surcharge. The assessee claimed that since the assessee has surrendered the registration u/s 12A of the Act and therefore, its income ... perused the material available on record. The sole dispute in this case is with respect to charging of tax whether it is on Maximum Marginal Rate (“MMR’) or as per normal rates of tax as applicable on Individual and HUF. The Co-ordinate bench of the Tribunal in the case

Vihar Trust, New Delhi vs. Deputy Commissioner of Income Tax, New Delhi

In the result, captioned appeals of the assessee in ITA Nos

ITA 4373/DEL/2025[2022-23]Status: DisposedITAT Delhi29 Jan 2026AY 2022-23

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 11Section 12ASection 143(1)Section 167BSection 250

applicable to the individual however, the while processing the return of income for all the three years, CPC has charged the tax at Maximum Marginal Rate (“MMR”) and levy surcharge. The assessee claimed that since the assessee has surrendered the registration u/s 12A of the Act and therefore, its income ... perused the material available on record. The sole dispute in this case is with respect to charging of tax whether it is on Maximum Marginal Rate (“MMR’) or as per normal rates of tax as applicable on Individual and HUF. The Co-ordinate bench of the Tribunal in the case

Vihar Trust, New Delhi vs. Deputy Commissioner of Income Tax, New Delhi

In the result, captioned appeals of the assessee in ITA Nos

ITA 4372/DEL/2025[2021-22]Status: DisposedITAT Delhi29 Jan 2026AY 2021-22

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 11Section 12ASection 143(1)Section 167BSection 250

applicable to the individual however, the while processing the return of income for all the three years, CPC has charged the tax at Maximum Marginal Rate (“MMR”) and levy surcharge. The assessee claimed that since the assessee has surrendered the registration u/s 12A of the Act and therefore, its income ... perused the material available on record. The sole dispute in this case is with respect to charging of tax whether it is on Maximum Marginal Rate (“MMR’) or as per normal rates of tax as applicable on Individual and HUF. The Co-ordinate bench of the Tribunal in the case

Alka Ashok Jagtap, Kalyan vs. Income Tax Officer, Kalyan

ITA 7524/MUM/2025[2009-10]Status: DisposedITAT Mumbai27 Jan 2026AY 2009-10

Bench: Shri Amit Shukla& Shri Makarand Vasant Mahadeokaralka Ashok Jagtap Income Tax Office C-304, Regency Avenue Rani Mansion Syndicate, Murbad Road, Vs. Kalyan, Kalyan Kalyan West, Thane- 421301, Kalyan Pan/Gir No. Ahtpj7760J (Applicant) (Respondent) Assessee By Shri Sunil Jain Revenue By Shri Surendra Mohan, Sr Dr Date Of Hearing 22.01.2026 Date Of Pronouncement 27.01.2026

Section 143(1)Section 143(3)Section 147Section 148Section 154Section 271(1)(c)Section 274

alleged bogus Long Term Capital Gain, while directing that the Short Term Capital Gain of Rs. 72,596/- be taxed at the maximum marginal rate. 17. Thus, the original addition which formed the very basis for initiation of penalty did not survive. 18. It is well settled that when

Proactive in & Out Advertising Private Limited, Mumbai vs. The Commissioner of Income Tax (Appeals)-26, New Delhi

Appeal is allowed

ITA 1025/DEL/2025[2020-21]Status: DisposedITAT Delhi15 Jan 2026AY 2020-21

Bench: Sh. Satbeer Singh Godara & Sh. Amitabh Shuklaita No. 1025/Del/2025 : Asstt. Year : 2020-21 Proactive In & Out Advertising Pvt. Vs Cit(A)-26, Ltd., B Wing, Samkeet Apartment, New Delhi Vileeparle (East), S.O. Mumbai, Maharashtra-400057 (Appellant) (Respondent) Pan No. Aaccp6306R Assessee By : None Revenue By : Ms. Ankush Kalra, Sr. Dr Date Of Hearing: 20.01.2026 Date Of Pronouncement: 20.01.2026 Order Per Satbeer Singh Godara: This Assessee’S Appeal For Assessment Year 2020-21, Arises Against The Cit(A)-26, New Delhi’S Order Dated 08.01.2025, In Proceedings U/S 143(3) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: NoneFor Respondent: Ms. Ankush Kalra, Sr. DR
Section 143(3)Section 40A(2)(b)

payee/director’s income tax return in the very assessment year 2020-21 declaring income of Rs.82,96,410/- assessable at the maximum marginal rate. This being the clinching factual position, we notice that various judicial precedents i.e. PCIT Vs. Future First Info Services (P.) Ltd. (2022) 145 taxmann.com ... issued way back on 18.06.1967 have settled the issue against the department that when both the payer and payee are assessed at maximum marginal rate, the impugned disallowance is not maintainable being a revenue neutral case. We thus reverse both the learned lower authorities’ action invoking section

Dy. Commissioner of Income Tax, Cgo Complex, Hapur Chungi vs. Kanpur Development Authority, Motijheel, Kanpur

ITA 4580/DEL/2025[2012-13]Status: DisposedITAT Delhi14 Jan 2026AY 2012-13

Bench: Yogesh Kumar U.S. & Shri Manish Agarwal

Section 11Section 143(3)Section 2Section 2(15)

1 ITA No. 4580/Del/2025 DCIT Vs. Kanpur Development Authority IN THE INCOME TAX APPELLATE TRIBUNAL DELHI (DELHI BENCH ‘B' NEW

Rajiv Pasari Family Beneficiary Trust, Kolkata vs. ITO, Ward-1(1), Kolkata

In the result, appeal of the assessee is allowed

ITA 363/KOL/2025[2024-25]Status: DisposedITAT Kolkata12 Jan 2026AY 2024-25

Bench: Shri George Mathanआयकर अपील सं/Ita No.363/Kol/2025 (नििाारण वर्ा / Assessment Year :2024-2025) Rajiv Pasari Family Beneficiary Trust, Vs Ito, Ward-1(1), Kolkata 62A, Hazra Road, Theatre Road, Kolkata-700019 Pan No. :Aactr 5490 F (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri Akkal Dudhewala, Ar राजस्व की ओर से /Revenue By : Shri Abhijit Adhikary, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 12/01/2026 घोषणा की तारीख/Date Of Pronouncement : 12/01/2026 आदेश / O R D E R This Is An Appeal Filed By The Assessee Against The Order Dated 23.01.2025 Passed By The Ld.Addl/Jcit(A), Faridabad, For The Assessment Year 2024-2025. 2. It Was Submitted By The Ld.Ar The Assessee Is A Private Beneficiary Trust. It Was Submission That The Income Of The Assessee Was Below Rs.50 Lakhs. It Was Further Submission That The Only Issue In The Assessee’S Appeal Was As To Whether Surcharge Is Leviable & If Leviable Whether The Slab Rate Should Be Applied Or The Maximum Rate Is To Be Applied. It Was Submission That The Cpc When Processing The Assessee’S Return Had Levied Surcharge Maximum Rate Of 25% Being Slab Rate. It Was Submission That The Issue Was Now Squarely Covered By The Decision Of The Special Bench Of This Tribunal In The Case Of Araadhya Jain Trust Vs. Ito, Reported In [2025] 173 Taxxmann.Com 343 (Mumbai-Trib)(Sb), Wherein In Para 32 The Special Bench Has Held As Follows :-

For Appellant: Shri Akkal Dudhewala, ARFor Respondent: Shri Abhijit Adhikary, Sr. DR

never fell for consideration before the Hon’ble Courts. The issue in dispute in those cases was primarily concerning what should be the maximum marginal rate and its applicability. The issue ‘whether the rate of surcharge would also be at the highest rate while computing tax at maximum marginal rate ... proposition of law. Thus, in the ultimate analysis, we hold, in case of Private Discretionary Trusts, whose income is chargeable to tax at maximum marginal rate, surcharge has to be computed on the income tax having reference to the slab rates prescribed in the Finance Act under the heading ‘surcharge

Deloitte Employees Welfare Trust, Mumbai vs. Income Tax Officer - Ward 22(1)(6), Mumbai

ITA 6691/MUM/2025[2022-23]Status: DisposedITAT Mumbai05 Jan 2026AY 2022-23

Bench: Shri Amit Shukla, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Ketan Ved a/w Shri NirajFor Respondent: Assessee by
Section 143(1)Section 164Section 164(1)Section 164(1)(iv)Section 167B

percent of Rs. 1,90,286. 2. Learned CIT(A) erred in observing that the assessee has calculated tax payable by applying MMR (Maximum marginal rate). 3. Learned CIT(A) ought to have appreciated the fact that levy of surcharge at the rate of 37 percent ... interest from fixed deposits. Assessee computed tax at normal rates, whereas the learned AO, CPC had completed the case of assessee @42.74% on maximum marginal rate (30% + 4% cess) including surcharge @37%, vide intimation u/s 143(1) dated 16th March 2023. Accordingly, a demand

Usha Girdharilal Jhunjhunwala, Mumbai vs. DCIT, Central Circle-1, Delhi

In the result, this ground

ITA 3499/DEL/2025[2021-22]Status: DisposedITAT Delhi05 Jan 2026AY 2021-22

Bench: Shri Satbeer Singh Godara & Shri Amitabh Shukla

Section 143(3)Section 69A

Revenue could hardly dispute that the assessee all along has been an income tax payee and getting assessed at the maximum marginal rate. There is further no denial to the fact that she had filed her cogent supportive evidence along with the details explaining sources of the cash seized

Narmada Trust, New Delhi vs. The Income Tax Officer, New Delhi

In the result, both the appeals of the assessee are allowed

ITA 2531/DEL/2025[2022-23]Status: DisposedITAT Delhi30 Dec 2025AY 2022-23

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Vasantiben Patel, AdvFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 11Section 12Section 12ASection 143(1)

issue to be decided in these appeals is as to 3. whether the assessee (AOP) could be subjected to levy of tax at maximum marginal rate (MMR) and levy of surcharge thereon. We have heard the rival submissions and peruse the materials 4. available on record. The assessee ... assessed to tax as per the rate prescribed normal slab rate, however, it was assessed at Maximum Marginal Rate (MMR). She also submitted that as per the circular No. 320 dated 11-01-1982[F. No. 131(31) /81-TP(Pt.) the tax is to be levied at the normal slab

Narmada Trust, New Delhi vs. The Income Tax Officer, New Delhi

In the result, both the appeals of the assessee are allowed

ITA 2530/DEL/2025[2021-22]Status: DisposedITAT Delhi30 Dec 2025AY 2021-22

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Vasantiben Patel, AdvFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 11Section 12Section 12ASection 143(1)

issue to be decided in these appeals is as to 3. whether the assessee (AOP) could be subjected to levy of tax at maximum marginal rate (MMR) and levy of surcharge thereon. We have heard the rival submissions and peruse the materials 4. available on record. The assessee ... assessed to tax as per the rate prescribed normal slab rate, however, it was assessed at Maximum Marginal Rate (MMR). She also submitted that as per the circular No. 320 dated 11-01-1982[F. No. 131(31) /81-TP(Pt.) the tax is to be levied at the normal slab

Ramkrishna Bajaj Charitable Trust, Mumbai vs. Deputy Commissioner of Income-Tax, Circle 26(1), Mumbai

ITA 6544/MUM/2025[2013-14]Status: DisposedITAT Mumbai24 Dec 2025AY 2013-14

Bench: Shri Amit Shukla, Jm & Shri Arun Khodpia, Am

For Appellant: Ms. Vasanti Patel, Adv. & MrFor Respondent: Assessee by
Section 10(34)Section 11Section 11(5)Section 12ASection 13(1)(d)Section 143(3)Section 164(2)Section 35ASection 80

support of its claim for exemption of Dividend Income. 1.3. The learned CIT(Appeals) erred confirming levy of tax on Dividend income at Maximum Marginal Rate of Tax on the ground that since the appellant is assessed in the status of trust under Section 12A, having violated the provisions ... section 11(5) r.w.s. 13(1)(d), is to be taxed at Maximum Marginal rate under Section 164(2) of the Act. 1.4. The learned CIT(Appeals) failed to appreciate that the appellant has not claimed benefits of Section 11 and 12 of the Act in the Return of Income

Punya Sthali Tirth Trust, Uttar Pradesh vs. ITO Ward (Exemption) Ward 2 (4), Delhi

In the result, appeal of the assessee is allowed, in the terms aforesaid

ITA 7070/DEL/2025[2019-20]Status: DisposedITAT Delhi24 Dec 2025AY 2019-20

Bench: Shri Vikas Awasthyआअसं.7070/धिल्ली/2025 (नि.व. 2019-20) Punya Sthali Tirth Trust, Gang Nahar Road Murad Nagar, Uttar Pradesh 201206 ...... अपीलार्थी/Appellant Pan: Aabtp-8479-P बिाम Vs. Income Tax Officer, Ward (Exemption)-2(4), R.No.2409, E-2 Block, Civic Centre, Minto Road, ..... प्रनिवादी/Respondent New Delhi 110002 अपीलार्थी द्वारा/Appellant By : Shri C.S Anand, Ms. Vaishnavi Yadav & Aastha Sharma, Advocates प्रधििािीद्वारा/Respondent By : Shri Manoj Kumar, Sr. Dr सुिवाई की निथर्थ/ Date Of Hearing : 15/12/2025 घोषणा की निथर्थ/ Date Of Pronouncement : 15/12/2025 आदेश/Order Per Vikas Awasthy, Jm:

For Appellant: Shri C.S Anand, Ms. Vaishnavi Yadav &For Respondent: Shri Manoj Kumar, Sr. DR
Section 133(6)Section 69A

without appreciating the facts confirmed the addition made by AO. He further submitted that AO has taxed the total income determined at the maximum marginal rate instead of applying slab tax rate. 3. Per contra, Shri Manoj Kumar representing the department submitted that the assessee neither participated in assessment proceedings ... liable to be deleted. 5. The next grievance of the assesee is that the AO has taxed interest income on maximum marginal rate instead of slab rate. Considering entire facts of the case, I deem it appropriate to restore the issue back to the file of AO for re-examination

New Surya Public School, Delhi vs. Deputy Assistant Commissioner of Income Tax Ward 31(4) Delhi, Delhi

In the result, the appeal of the assessee is accordingly allowed in above terms for statistical purposes

ITA 5082/DEL/2025[2018-19]Status: DisposedITAT Delhi24 Dec 2025AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

Section 11Section 139(1)Section 143(1)Section 250

where in an identical situation an AOP inadvertently filed ITR-7 instead of ITR-5, leading CPC to tax it at maximum marginal rates without allowing expenses. The Ld. Co-ordinate bench has held that the Income Tax Authorities are ‘not supposed to punish assessees for their bona fide mistake

Rahulkumar Bajaj Charitable Trust, Mumbai vs. Deputy Commissioner of Income Tax, Mumbai

In the result, the appeal filed by the assessee is hereby partly allowed

ITA 1770/MUM/2025[2023-24]Status: DisposedITAT Mumbai23 Dec 2025AY 2023-24

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Respondent: Shri R. R. Makwana, Addl. CIT
Section 11Section 12ASection 139(1)Section 143(1)Section 250

catena of decisions. 8. The learned Departmental Representative ('ld. DR' for short) for the revenue controverted the said fact and stated that the Maximum Marginal Rate (MMR) was applicable in assessee’s case according to first Schedule, Part I of Finance Act, 2020 which is applicable for the relevant assessment ... year. Further, the ld. DR contended that the Maximum Marginal Rate (MMR) are to be calculated as per Section 2(29C) of the Act r.w.s. 164 of the Act in accordance with the Finance Act of that year, where the rate of tax of the highest slab along with

Rahulkumar Bajaj Charitable Trust, Mumbai vs. Deputy Commissioner of Income Tax, Mumbai

In the result, the appeal filed by the assessee is hereby partly allowed

ITA 1769/MUM/2025[2022-23]Status: DisposedITAT Mumbai23 Dec 2025AY 2022-23

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Respondent: Shri R. R. Makwana, Addl. CIT
Section 11Section 12ASection 139(1)Section 143(1)Section 250

catena of decisions. 8. The learned Departmental Representative ('ld. DR' for short) for the revenue controverted the said fact and stated that the Maximum Marginal Rate (MMR) was applicable in assessee’s case according to first Schedule, Part I of Finance Act, 2020 which is applicable for the relevant assessment ... year. Further, the ld. DR contended that the Maximum Marginal Rate (MMR) are to be calculated as per Section 2(29C) of the Act r.w.s. 164 of the Act in accordance with the Finance Act of that year, where the rate of tax of the highest slab along with