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Amendment to section 36(1)(va)/43B imposing liability on Assessee applicable from 01.04.2021
Case Law Details
- Case Name
- Navrathan Jewellers Pvt. Ltd. Vs ADIT (ITAT Bangalore)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2019-20
- Courts
- All ITAT, ITAT Bangalore
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Navrathan Jewellers Pvt. Ltd. Vs ADIT (ITAT Bangalore)
Explanatory memorandum to the Finance Act, 2021 proposing amendment in section 36(1)(va) as well as section 43B is applicable only from 01.04.2021. These provisions impose a liability on an assessee and therefore cannot be construed as applicable with retrospective effect unless the legislature specifically says so. In the decisions referred to by us in the earlier paragraph of this order on identical issue the tribunal has taken a view that the aforesaid amendment is applicable only prospectively i.e., from 1.4.2021. We a...
