In the result, appeal of the assessee is allowed
Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)
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