In the result, the appeal of the assessee is partly allowed and that of the Revenue is dismissed
Bench: Shri Chandra Mohan Garg & Shri Girish Agrawal
220 (Mum.) in which it was observed as under : 37 ITA.No.105 & 116/PAN./2018 Sociedade De Fomento Industrial Pvt. Ltd., Margao, Goa. "9. The legal proposition canvassed by the learned counsel, however, does no longer hold good in view of retrospective amendment with effect from 1-6-1976 in section 9 brought out by the Finance Act, 2010. Under