CIT v. S.G. Pgnatale
124 ITR 391High Court1980#523 most cited
What is CIT v. S.G. Pgnatale authority for?
An Explanation to Section 9(1)(ii) of the Income Tax Act that widens the scope of the provision, rather than merely clarifying it, cannot be applied retrospectively to assessment periods prior to its effective date. Assessments must be made according to the law in force at the relevant time.
181
judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2005 to 2025.
Also referred to as
CIT v. S.G. Pgnatale · 124 ITR 391 · Section 9(1)(ii) · Explanation to Section 9(1)(ii) · Retrospective amendment · Clarificatory amendment · Scope widening amendment · Applicability of law · Law in force at relevant time · Assessment year applicability · Non-retrospective application
