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In the result, the appeal of the assessee is allowed
Bench: Shri P.M. Jagtap(Kz) &Shri A. T. Varkey] Assessment Year: 2019-20
23. This being the case, Explanation 3C is clarificatory - it explains Section 43B(d) as it originally stood and does not purport to add a new condition retrospectively, as has wrongly been held by the High Court. 24. Third, any ambiguity in the language of Explanation 3C shall be resolved in favour of the assessee as per Cape Brandy