Amendment to Section 40(a)(ia) vide Finance Act, 2014 is Not Retrospective  

Purulia Central Co-Op Bank Ltd Vs ACIT (ITAT Kolkata) Sole issue for determination before the Tribunal is ‘whether the amendment made by the Finance (No. 2) Act, 2014 to Section 40(a)(ia) of the Act is to be applied retrospectively or not’. ITAT find that the issue is squarely covered by the decision of the Hon’ble Supreme Court in the case of “Shree Choudhary Transport Company vs. Income Tax Officer” [2020] 118 com 47 (SC), wherein, the Hon’ble Supreme Court has held that the amendment made by the Finance (No.2) Act, 2014, could not be stretched anterior to the date of its substit...