M/s.V.R.Farms Pvt Ltd vs. Deputy Commissioner of Income Tax

The appeals are dismissed

Bench: P.SAM KOSHY,SUDDALA CHALAPATHI RAO

3. All the appeals are in respect of assessment years prior to the amendments to Explanation 1 after section 234B(1) and to the Explanation after section 234C(1) of the Income Tax Act, 1961 (hereinafter referred to as ―the said Act‖) by virtue of the Finance Act, 2006, w.e.f. 01.04.2007. According to the learned counsel for the appellant/revenue, after

Commissioner of Income tax-V, vs. M/s. INTRACK INC,

3. The substantial questions of law that arise for consideration in all these appeals is whether, the amendment to Section 40(a)(ia) by the Finance Act, 2010, which is given effect from 01.04.2010 is retrospective in nature. 4. Prior to the amendment, the said provision read as under:- Section 40(a)(ia) : any interest, commission or brokerage, rent, royalty