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“retrospective amendment”

MiscellaneousGeneralGeneral452 judgments

SHARP GARUDA FARM EQUIPMENTS PVT.LTD,COIMBATORE vs. DCIT, CORPORATE CIRCLE 1, , COIMBATORE

In the result, the appeal filed by the assessee is allowed

ITA 3394/CHNY/2025[2020-21]Status: DisposedITAT Chennai17 Mar 2026AY 2020-21

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri T.N. Seetharaman, AdvocateFor Respondent: Ms. T.Mythili, JCIT
Section 143(2)Section 143(3)Section 250Section 270Section 270ASection 270A(8)Section 274Section 37

admitted income of Rs. 14,38,20,240/- 3. The authorities below failed to see that on coming to know of the proposed retrospective amendment to Sec.40(a)(ii) by the Finance Bill, 2022 treating education cess at par with tax, during the course of the assessment proceedings, the appellant ... such circumstances penalty u/s 270A is not leviable. 4. The appellant submits that the variation in the total income due to retrospective amendment to Sec. 40(a)(ii) by the Finance Act, 2022 cannot give rise to levy of penalty u/s 270 A of the Act. 5. The appellant submits

SHREE SWATI TEXDYES PVT. LTD.,AHMEDABAD vs. THE DY. CIT, CIRCLE-4(1)(1), AHMEDABAD

In the result, the appeal of the assessee is allowed

ITA 2222/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad12 Mar 2026AY 2020-21

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Respondent by: Shri Rameshwar P Meena, Sr. DRFor Respondent: Shri Rameshwar P Meena, Sr. DR
Section 14ASection 270ASection 40

DCIT Asst. Year –2020-21 - 2– as the Cess was voluntarily withdrawn by the appellant on suo moto basis on account of proposed retrospective amendment in law. 03. The Ld. CIT(A) has erred in confirming penalty under section 270A of the Act of Rs.3,69,579 on account ... DCIT Asst. Year –2020-21 - 3– 423 ITR 426 (Bom) and therefore the claim was bona fide. It was further submitted that after the retrospective amendment brought by the Finance Act, 2022 clarifying that cess forms part of tax under section 40(a)(ii) of the Act, the assessee voluntarily

INCOME TAX OFFICER, CHENNAI vs. SHANMUGANATHAN DEVASENAPATHY, CHENNAI

In the result, the appeal filed by the revenue is allowed for

ITA 3880/CHNY/2025[2017-18]Status: DisposedITAT Chennai20 Feb 2026AY 2017-18

Bench: Shri Inturi Rama Rao & Shri Manu Kumar Giriआयकर अपील सं./Ita No 3880/Chny/2025 "नधा"रण वष"/Assessment Year: 2017-18 Ito, Che-W-(112)(3) V. Shanmuganathan Chennai-600006 Devasenapathy 6E Thiruvallulvar, Nagar Tondiarpet, Chennai 600081 [Pan:Afzpd 2010 F] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: NoneFor Respondent: Ms. R. Anitha, Addl. CIT
Section 142(1)Section 147Section 148Section 69A

Assessing Officer u/s. 147 read with 144 and 144B of the Act. 5. However, it is observed that the Budget 2026 has introduced retrospective amendments aimed at addressing and nullifying the ITO (Vs.) SHANMUGANATHAN DEVASENAPATHY (:: 4 :) controversy concerning jurisdiction between the Jurisdictional Assessing Officer (JAO) and the Faceless Assessing Officer ... file, directing him to await the outcome of the decisions of the Hon’ble Supreme Court and/or the concerned High Courts considering retrospective amendments and thereafter pass an order in accordance with law. 6. In the result, the appeal filed by the revenue is allowed for statistical purposes. Order pronounced

NAVALMAL FIRODIA MEMORIAL HOSPITAL TRUST,PUNE vs. INCOME TAX OFFICER, EXEMPTION WARD 1(2), PUNE

In the result, the appeal filed by the assessee is allowed

ITA 2460/PUN/2025[2023-24]Status: DisposedITAT Pune10 Feb 2026AY 2023-24

Bench: the learned CIT(A), the same has neither been taken note of or distinguished in any manner. Not following the binding Judicial precedent of the Jurisdictional ITAT Pune is gross impropriety in law. Ground No. 2: The Appellant craves leave to add, alter, amend or withdraw all or any of the Grounds of Appeal herein and to submit such statements, documents and papers as may be considered necessary either at or before the appeal hearing.”

For Appellant: Shri Shrenik GandhiFor Respondent: Shri Manish Sinha (Virtual)
Section 11Section 11(2)(a)Section 11(3)Section 11(3)(c)Section 12ASection 143(1)

find the Hon'ble Supreme Court in the case of Vatika Township (P.) Ltd.(supra) on the issue of interpretation of taxing statutes about retrospective amendment and prospective amendment, has held as under: "30. A legislation, be it a statutory Act or a statutory Rule or a statutory Notification

ACITLTU-2, CHENNAI vs. ASHOK LEYLAND LIMITED, CHENNAI

In the result, the appeal filed by the Revenue is partly allowed and the appeal filed by the assessee is partly allowed for statistical purposes

ITA 945/CHNY/2018[2009-10]Status: DisposedITAT Chennai05 Feb 2026AY 2009-10

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.895/Chny/2018 िनधा"रण वष"/Assessment Year: 2009-10 Ashok Leyland Limited, Vs. The Deputy Commissioner Of 1, Sardar Patel Road, Guindy, Income Tax, Chennai 600 032. Company Circle – Ltu, Chennai. [Pan: Aaaca4651L] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.945/Chny/2018 िनधा"रण वष"/Assessment Year: 2009-10 The Assistant Commissioner Of Vs. Ashok Leyland Limited, Income Tax, 1, Sardar Patel Road, Guindy, Large Taxpayer Unit – 2, Chennai. Chennai 600 032. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Assessee By : Shri Vikram Vijayaraghavan, Advocate (Virtual) ""थ" की ओर से/Respondent By : Shri Ar V Sreenivasan, Cit सुनवाई की तारीख/ Date Of Hearing : 10.11.2025 घोषणा की तारीख /Date Of Pronouncement : 05.02.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Cross Appeals Filed By The Assessee & The Revenue Are Directed Against The Order Dated 28.12.2017 Passed By The Ld.

For Appellant: Shri Vikram Vijayaraghavan, AdvocateFor Respondent: Shri AR V Sreenivasan, CIT

ruled out in providing guarantees and hence the transaction involving issuance of corporate guarantee is covered by the definition of international transaction consequent to retrospective amendment made by the Finance Act, 2012 and, accordingly adjustments are required to be made for guarantee commission. The relevant findings taken note ... Limited. In the said case, the Revenue contended that the transaction of providing Corporate Guarantee is covered by the definition of international transaction after retrospective amendment made by Finance Act, 2012. The assessee argued that the Corporate Guarantee is an additional guarantee, provided by the Parent company. It does

ASHOK LEYLAND LIMITED,CHENNAI vs. DCIT COMPANY CIRCLE 1 (1), CHENNAI

In the result, the appeal filed by the Revenue is partly allowed and the appeal filed by the assessee is partly allowed for statistical purposes

ITA 895/CHNY/2018[2009-10]Status: DisposedITAT Chennai05 Feb 2026AY 2009-10

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.895/Chny/2018 िनधा"रण वष"/Assessment Year: 2009-10 Ashok Leyland Limited, Vs. The Deputy Commissioner Of 1, Sardar Patel Road, Guindy, Income Tax, Chennai 600 032. Company Circle – Ltu, Chennai. [Pan: Aaaca4651L] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.945/Chny/2018 िनधा"रण वष"/Assessment Year: 2009-10 The Assistant Commissioner Of Vs. Ashok Leyland Limited, Income Tax, 1, Sardar Patel Road, Guindy, Large Taxpayer Unit – 2, Chennai. Chennai 600 032. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Assessee By : Shri Vikram Vijayaraghavan, Advocate (Virtual) ""थ" की ओर से/Respondent By : Shri Ar V Sreenivasan, Cit सुनवाई की तारीख/ Date Of Hearing : 10.11.2025 घोषणा की तारीख /Date Of Pronouncement : 05.02.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Cross Appeals Filed By The Assessee & The Revenue Are Directed Against The Order Dated 28.12.2017 Passed By The Ld.

For Appellant: Shri Vikram Vijayaraghavan, AdvocateFor Respondent: Shri AR V Sreenivasan, CIT

ruled out in providing guarantees and hence the transaction involving issuance of corporate guarantee is covered by the definition of international transaction consequent to retrospective amendment made by the Finance Act, 2012 and, accordingly adjustments are required to be made for guarantee commission. The relevant findings taken note ... Limited. In the said case, the Revenue contended that the transaction of providing Corporate Guarantee is covered by the definition of international transaction after retrospective amendment made by Finance Act, 2012. The assessee argued that the Corporate Guarantee is an additional guarantee, provided by the Parent company. It does

SOUTHERN ENTERPRISES,CHENNAI vs. ACIT NON CORPORATE WARD 22, CHENNAI

In the result, appeal filed by the assessee is allowed

ITA 2941/CHNY/2017[2009-10]Status: DisposedITAT Chennai04 Feb 2026AY 2009-10

Bench: Shri Aby T. Varkey & Ms. Padmavathy. S

For Appellant: Ms. S. Sanchitha for Mr. R. SivaramanFor Respondent: Mr. Praveen. S, JCIT
Section 10BSection 142(1)Section 143(2)Section 143(3)Section 147Section 148

Asstt. CIT [2013] 33 taxmann.com 67/354 ITR 562 (Guj.) 13. The third reason is to be referred only for summary rejection. Third ground was retrospective amendment in section 115JB of the Act. Surely, beyond a period of four years this cannot be a ground for reassessment on assessment. Such legal

CAPGEMINI TECHNOLOGY SERVICES INDIA LIMITED (SUCCESSOR TO LIQUIDHUB INDIA PRIVATE LIMITED),PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(1), PUNE, PUNE

In the result, the Appeal filed by the Assessee is allowed

ITA 2753/PUN/2025[2020-21]Status: DisposedITAT Pune19 Jan 2026AY 2020-21

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2753/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 Capgemini Technology V Assessment Unit, Services India S Income Tax Limited(Successor To Liquid Department. Hub India Private Limited), Plot No.14, Rajiv Gandhi Infotech Park, Hinjewadi, Phase Iii, Midc Sez, Village Man, Taluka Mulshi, District Pune – 411057. Pan: Aaacl8943J Appellant/ Assessee Respondent /Revenue Assessee By Shri Sudin Sabnis & Shri Siddhesh Khandalkar Revenue By Shri Madhukar Anand-Jcit(Through Virtual) Date Of Hearing 05/01/2026 Date Of Pronouncement 19/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2020-21 Dated 02.09.2025 Emanating From The Penalty Order Passed Under Section

Section 115JSection 143(3)Section 155Section 155(18)Section 18Section 250Section 270ASection 270A(6)(a)Section 40

However, vide letter dated 22 June 2022, it withdrew the claim of allowability of 'Health and Education Cess' on account of the retrospective amendment made to the provisions of section 40(a)(ii) of the Act. The sole addition made to the income of LHI, during the said assessment proceedings ... April 01, 2022. 7.2. Considering the suo-moto disallowance of Health and Education Cess of LHI, the Company computed the tax impact of such retrospective amendment as follows in its opening balance itself. The Opening balance of MAT credit of the Company thus stood reduced on account of the said

ACIT, CIRCLE-2(1)(1),AGRA, AGRA vs. EMCO EXPORTS, AGRA

In the result, revenue’s appeal stands dismissed

ITA 415/AGR/2025[2020-21]Status: DisposedITAT Agra15 Jan 2026AY 2020-21

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singhassessment Year: 2020-21

Section 195Section 250Section 40Section 9

that the law laid down by the Apex Court in the case of Ishikawajima Harima Heavy Industries Limited (supra) still holds good despite the retrospective amendment to section 9 of the Act. In our opinion, the requirement of services of the non- resident being rendered in India and being utilized

DY. COMMISSIONER OF INCOME TAX, CIRCLE-16(1), C.R BUILDING, I.P ESTATE, NEW DELHI vs. MD EQUIPMENT PVT. LTD. , INTERNATIONAL TRADE TOWER NEHRU PLACE, SOUTH DELHI

In the result, the appeal of the Revenue is dismissed

ITA 3523/DEL/2025[2023]Status: DisposedITAT Delhi05 Jan 2026
Section 10ASection 115JSection 139(4)Section 143(1)Section 143(1)(v)Section 44A

application of an amended proviso is justified."}} proviso is justified."}} viso is justified, considering the CBDT's extension of time and the law regarding retrospective amendments

INSIGHT PRINT COMMUNICATIONS PRIVATE LIMITED,MUMBAI vs. THE PCIT, MUMBAI-4, MUMBAI

In the result, appeal of the assessee is dismissed

ITA 3384/MUM/2025[2020-21]Status: DisposedITAT Mumbai31 Dec 2025AY 2020-21

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2020-21 Insight Print Communications Pcit, Mumbai-4 Private Limited A-14, Synthofine Industrial Estate, Behind Virvani Industrial Estate, Vs. Dindoshi, Off Aarey Road, Goregaon (East), Mumbai – 400063 (Pan: Aabci6530P) (Appellant) (Respondent) Present For: Assessee : Shri Lalchand Choudhary, Ca Revenue : Shri R.A. Dhyani, Cit Dr Date Of Hearing : 08.10.2025 Date Of Pronouncement : 31.12.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Revisionary Order By Ld. Pcit, Mumbai-4, Vide Order No. Itba/Rev/F/Rev5/2024- 25/1074740466(1), Dated 20.03.2025 Passed U/S. 263 Of The Income- Tax Act, 1961 (Hereinafter Referred To As The “Act”) Against The Assessment Order By Assessment Unit, U/S. 143(3) R.W.S.144B Of The Act, Dated 22.09.2022, For Ay 2020-21. 2. Grounds Taken By Assessee Are Reproduced As Under: 1. The Appellant Prefers The Following Appeal Against The Order Dated 20/03/2025 Of The Principal Commissioner Of Income Tax, Mumbai-4 (Hereinafter Referred To As "The Pcit ") Passed Under Section 263 Of The Income Tax Act, 1961 ("The Act"). Each Of The Grounds Is In Alternative & Without Prejudice To Other.

For Appellant: Shri Lalchand Choudhary, CAFor Respondent: Shri R.A. Dhyani, CIT DR
Section 142(1)Section 143(3)Section 263Section 37Section 40

income. He noted that said expense cannot be claimed as an expenditure u/s. 37 r.w.s. 40(a)(ii) of the Act, in view of retrospective amendment made by Finance Act, 2022 to Section 40(a)(ii), effective from 01.04.2005. Thus, the expenditure towards Education Cess claimed by the assessee ... much prior to the date when the assent of Hon’ble President of India was received in respect of Finance Act, 2022 whereby retrospective amendment was brought in the section 40(a)(ii). 4. Ld. PCIT after considering the submissions made by the assessee came to conclusion that assessee

DCIT, BANGALORE vs. M/S THOMSON REUTERS INDIA SERVICES PVT. LTD.,, BANGALORE

In the result, appeal filed by revenue in IT(TP)

ITA 843/BANG/2015[2010-11]Status: DisposedITAT Mumbai31 Dec 2025AY 2010-11

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 10ASection 10A(2)Section 143(3)

towards the use of copyrighted article and not for use of copyright. f) That the learned AO also failed to appreciate that a retrospective amendment cannot be made applicable to disallow the claim for depreciation under section 40(a)(i) / 40(a)(ia) of the Act. g) Without prejudice

GRANULES INDIA LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(1), HYDERABAD

In the result, the appeal filed by the assessee company is allowed

ITA 1295/HYD/2025[2020-21]Status: DisposedITAT Hyderabad24 Dec 2025AY 2020-21

Bench: Shri Manjunatha G & Shri Ravish Soodआ.अपी.सं /Ita No.1295/Hyd/2025 (िनधा"रण वष"/Assessment Year:2020-21) M/S. Granules India Limited, Dy. Commissioner Of Income Vs. Hyderabad. Tax, Pan : Aaacg7369K Circle 2(1), Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Y.V. Bhanu Narayan Rao, C.A. राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr-Dr सुनवाई की तारीख/Date Of Hearing: 22/12/2025 घोषणा की तारीख/Pronouncement: 24/12/2025

For Appellant: Shri Y.V. Bhanu Narayan RaoFor Respondent: Dr. Sachin Kumar, SR-DR
Section 139(1)Section 143(1)Section 143(3)Section 154Section 155(18)Section 270A

ought to have appreciated the fact that the assessee had given up the claim of education cess of Rs.4,81,53,591/- pursuant to retrospective amendment enacted vide Finance Act, 2022 before the completion of the assessment, and ought to have deleted the penalty levied u/s 270A ... supra), wherein it was held that “cess” (Health and Education cess), whenever paid in relation to business, is a deductible expense, had thereafter been retrospectively amended by the Finance Act, 2022 w.r.e.f ITA No.1295/Hyd/2025 11 01/04/2005, clarifying that “tax” includes “cess” for purpose of Section

JEKPL PVT. LTD. (ERSTWHILE JUBILANT ENERGY (KHARSANG) PVT LTD),NOIDA vs. DEPUTY COMMISSIONER OF INCOME TAX, NEW DELHI, NEW DELHI

In the result, appeal of the assessee for ITA No

ITA 3250/DEL/2024[2011-12]Status: HeardITAT Delhi12 Dec 2025AY 2011-12

Bench: Shri Anubhav Sharma& Shri Amitabh Shukla

Section 143(3)Section 80Section 80I

deduction was allowed to the assessee in both years. The deduction has been disallowed in the present assessment year only on the strength of retrospective amendment carried out in section 80 IB (9) by introduction of the explanation to this section. Thus, if the explanation is to be read

JEKPL PRIVATE LIMITED (ERSTWHILE JUBILANT ENERGY (KHARSANG) PVT LTD),NOIDA vs. DEPUTY COMMISSIONER OF INCOME TAX, NEW DELHI, NEW DELHI

In the result, appeal of the assessee for ITA No

ITA 3247/DEL/2024[2010-11]Status: HeardITAT Delhi12 Dec 2025AY 2010-11

Bench: Shri Anubhav Sharma& Shri Amitabh Shukla

Section 143(3)Section 80Section 80I

deduction was allowed to the assessee in both years. The deduction has been disallowed in the present assessment year only on the strength of retrospective amendment carried out in section 80 IB (9) by introduction of the explanation to this section. Thus, if the explanation is to be read

NUNHEMS NETHERLANDS B.V.,NAPOLEONSWEG, NETHERLANDS vs. ASSISTANT COMMISSIONER OF INCOME TAX,, INTERNATIONAL TAXATION, GURGAON

In the result, appeal of the assessee in ITA No

ITA 3382/DEL/2023[2021-22]Status: DisposedITAT Delhi08 Dec 2025AY 2021-22

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Nageshwar Rao, AdvFor Respondent: Ms. Anjula Jain, CIT-DR
Section 143(3)Section 144C(13)Section 270Section 9(1)(vi)

section 9(1)(vi) makes it clear that possession or location of equipment is immaterial for taxing the same as royalty. The retrospective amendment has removed all doubts in so far as the expression 'use or right to use' has to be understood in the context of possession, control

M/S. JAYSHRI EXPORTS (INDIA) LTD.,JETPUR vs. THE DCIT, CIRCLE-1, RAJKOT

In the result, appeal filed by the assessee is allowed

ITA 56/RJT/2020[2004-05]Status: DisposedITAT Rajkot25 Nov 2025AY 2004-05

Bench: Dr. Arjun Lal Sainiआयकरअपील सं /Ita No. 56/Rjt/2020 िनधा"रण वष"/Assessment Year : 2004-05 बनाम/ M/S. Jayshri Exports (India) The Deputy Commissioner Of Dhoraji Road, Navagadh, Income-Tax Circle-1, Rajkot Vs Jetpur, Gujarat - 360370 "ायीलेखासं./जीआइआर सं./Pan/Gir No.: Aabfj8267B (अपीलाथ"/Assessee) (""थ"/Respondent)

For Appellant: Shri Chetan Agarwal, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 143(1)Section 143(2)Section 143(3)Section 250Section 28Section 80HSection 80I

amendment and not in respect of earlier assessment years of the assessees whose export turnover is above Rs.10 crore. In other words, the retrospective amendment should not be detrimental to any of the assessees.” Against the High Court judgment these SLPs are filed by the Union of India. Mr. Mukul

CAPGEMINI TECHNOLOGY SERVICES INDIA LIMITED ( SUCCESSOR OF ARICENT TECHNOLOGIES HOLDINGS LIMITED),PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(1), PUNE, PUNE

In the result, the appeal of the assessee is allowed

ITA 1260/PUN/2025[2020-21]Status: DisposedITAT Pune24 Nov 2025AY 2020-21

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Vyomesh PathakFor Respondent: Shri Vidya Ratna Kishore
Section 143(3)Section 154Section 155(18)Section 270ASection 270A(2)Section 270A(6)(a)Section 270A(7)Section 270A(8)Section 270A(9)

levied u/s 270A of the Act in the hands of assessee for claim of Education Cess which was brought to tax based on the retrospective amendment in Act. Accordingly, we hereby direct the AO to delete the penalty.‖ 10. Similar view has been taken by the Bangalore ITAT

DEPUTY COMMISSIONER OF INCOME TAX, KOLKATA vs. SANTOSH PROMOTERS PRIVATE LIMITED, KOLKATA

In the result, the appeal of Revenue is dismissed

ITA 94/KOL/2024[2012-13]Status: DisposedITAT Kolkata20 Nov 2025AY 2012-13

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Dy. Commissioner Of Income Tax Santosh Promoters Private O/O The Dcit, Cc-1(1), Limited Room No.305, 3Rd Floor, 145, Rash Behari Avenue, Vs. Aayakar Bhawan Poorva, Gariahat, Kolkata-700029 Kolkata-700107 West Bengal West Bengal (Appellant) (Respondent) Pan No. Aadcs7546M Assessee By : Shri Siddharth Agarwal, Ar Revenue By : Shri Sandeep Lakra, Dr Date Of Hearing: 29.10.2025 Date Of Pronouncement: 20.11.2025

For Appellant: Shri Siddharth Agarwal, ARFor Respondent: Shri Sandeep Lakra, DR
Section 132Section 133(6)Section 50C

Rather it is only a procedural amendment. Therefore, even when the statute does not specifically state so, such amendment are in the nature of retrospective amendment and these should be treated as effective from the date when 50C was introduced in the statute, i.e. w.e.f. 01.04.2003. As in the appellant

VIJIT SINGH,JAIPUR vs. ITO WARD 3(2) JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed

ITA 1246/JPR/2025[2009-10]Status: DisposedITAT Jaipur17 Nov 2025AY 2009-10
For Appellant: Shri Shrawan Kumar Gupta, AdvFor Respondent: Shri Gaurav Awasthi, JCIT
Section 147Section 234ASection 250

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