Second proviso to section 40(a)(ia) must be read and given effect to retroactively

Principal CIT Vs M/s. Manoj Kumar Singh (Allahabad High Court) It is not disputed that Section 40(a)(ia) proviso is for the benefit of Assessee. When a provision has been made in fiscal statute for benefit of Assessee, in absence of any express provision or a provision which by necessary implication gives a different impression, such provision which is beneficial to Assessee must be read and given effect to retroactively. FULL TEXT OF THE HIGH COURT ORDER / JUDGMENT 1. Heard Sri Alok Mathur, learned counsel for appellant and Sri Pradeep Agrawal, learned counsel for respondent. 2. This appea...