Amendment to Section 40(a)(ia) restricting disallowance to 30% is retrospective

Punabhai G. Pardava Vs ITO (ITAT Rajkot) Assessee contended that the disallowance should be restricted to the tune of 30% of the rent paid under the provisions of section 40(a)(ia) read with section 194-I of Income Tax Act. The amendment was brought by the Finance Act (No. 2) 2014 effective from 1-4-2015 whereas the year before us relates to the assessment year 2012-13. Thus, the issue which arises for consideration is whether amendment brought by Finance Act, 2014 restricting disallowance of expenditure to 30%, since with object to remove hardship, can by necessary implication be considered a...