The assessee surrendered the additional income during the survey. The income surrendered were partly in nature of business income and partly deemed income. The assessee had set off debit entries and business loss against the same. The Assessing Officer treated the entire additional income surrendered as deemed income as provided under sections 69, 69A, 69B and 69C separately and charged to tax under section 115BBE and  denied the set off of losses . On appeal the Tribunal held that  the amendment made to section 115BBE denying the benefit of set off of losses with effect from 1-4-2017 was retrospective in nature, it is prospective, hence the assessee is entitle to set off the losses against deemed income assessed under S. 69 69A and 69C of the Act. Followed, PCIT v. Khushi Ram & Sons Foods (P.) Ltd. in (ITA No. 126 of 2015, dt. 29-7-2016 ( P& H) ( HC))  ( AY. 2013 -14 , 2014 -15)