RAMESH JAISINGHANI,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -5(2), MUMBAI
In the result, appeal of the assessee is allowed
ITA 980/MUM/2025[2020-21]Status: DisposedITAT Mumbai10 Oct 2025AY 2020-21
Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)
Section 143(3)Section 244ASection 50(2)(ec)Section 55(2)(aa)Section 55(2)(ac)Section 55(2)(as)Section 56(2)(ac)
applied prospectively Le it should be applied to OFS transactions after 22 July 2024:
erred in applying the amended provision of Section 56(2)(ac) of the Act, without appreciating that the amended provisions cannot be applied retrospectively since it creates a new class of "assessee" as well as burdens
