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Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Girish Agrawal
15% of such surplus income and be taxed accordingly. 10. The assessee vide letter dated 20.12.2019 pointed out the proviso to section 12A(2) of the I. T. Act 1961 and claimed that provision of section 11 and 12 shall apply in its case and no action u/s 147 can be initiated in view of the said proviso. In this