SOCIEADADE DE FOMENTO INDL. PVT. LTD.,MARGAO vs. JOINT COMMISSIONER OF INCOME TAX, MARGAO RANGE, MARGAO
In the result, the appeal of the assessee is partly allowed and that of the Revenue is dismissed
ITA 105/PAN/2018[2010-11]Status: DisposedITAT Panaji12 Sept 2022AY 2010-11
Bench: Shri Chandra Mohan Garg & Shri Girish Agrawal
For Appellant: Sh. Nishant Thakkar, AdvocateFor Respondent: Sh. Ranjan Kumar, CIT-DR
Section 143(1)Section 143(2)Section 14A
section 9."
6. It is an undisputed fact that the Finance Act, 2010 received the assent of the President on 8.5.2010 and all the payments have been made by the Assessee to the non-resident party prior to receiving of assent of the President making the retrospective amendment by adding explanation to Sec. 9(1). At the time when