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Bench: Shri B.M. Biyani & Shri Paresh M. Joshi
11. The ld. DR submitted that as per various judicial decisions the ratio is that the legislations which modified accrued rights or imposed disabilities were to be treated as prospective in nature unless they were accounting for an obvious omission, or explaining a former legislation. In the present case, section 200(3) provides for statutory liability for depositing the TDS