Amendment to DTAA can’t be given retrospective effect unilaterally

IN THE ITAT MUMBAI Abu Dhabi Commercial Bank Ltd. V/s. ADIT (IT) – 1(1), Mumbai IT APPEAL NOS. 1996, 2205, 2851, 3925, 4304 & 5017 (MUM.) OF 2004 AND 3462, 3857 & 4022 (MUM.) OF 2010 C.O. NOS. 115 & 414 (MUM.) OF 2004 AND 48 (MUM.) OF 2005 [ASSESSMENT YEARS 1995-96 TO 2000-01] July 20, 2012 ORDER Per Bench – These are bunch of cross appeals and cross objections filed by the assessee for the assessment years 1995-1996 to 2000-2001. Since the issues in all the appeals are common, therefore, for the sake of convenience, all these appeals are being disposed...