Sec 40(a)(ia) amendment extending TDS payment due date U/s. 139(1) is Retrospective

This Appeal under Section 260­A of the Income Tax Act, 1961 (the Act), challenges the order dated 16th January, 2014 passed by the Income Tax Appellate Tribunal (the Tribunal). The impugned order dated 16th January, 2014 is in respect of Assessment Year 2009­-10. 2 The Revenue urges the following question of law for our consideration: “ Whether on the facts and in the circumstance of the case and in law, the Tribunal was justified in holding that amendment to Section 40(a)(ia) of the Act by the Finance Act, 2010 was retrospective in operation without appreciating that the law to be applied...