Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra
Section 37 of the Act was inserted by the Finance (No. 2) Act, 2014, w.e.f. 1.4.2015 and was applicable from Assessment Year 2015-16 and that the said provision was not applicable in the Assessment Year 2012-13 and that the application of the said provision is only prospective. 9. For that the ld. Commissioner of Income Tax (Appeal