Amended provisions of Section 154 cannot be applied with retrospective effect

A R Transport Vs ADIT (ITAT Jabalpur) The view recorded in the impugned order/s on the merits of the additions – even as the same agrees with that expressed by the Tribunal in Nikhil Mohine (supra)(see para 3.2 of this order), is of little consequence in view of the limited scope of an adjustment u/s. 143(1), the law on which is well-settled, with the Explanatory Notes to the Provisions of the Finance Bill, 2021 itself admitting of a conflict of judicial opinion, explaining that to be the reason for effecting the amendments per the said Explanations. The only circumstance justifying the impu...