Assessee cannot be asked to comply with a provision not in force at relevant time

CIT Vs. NGC Networks (India) Pvt. Ltd (Bombay High Court)

A party cannot be called upon to perform an impossible Act i.e. to comply with a provision not in force at the relevant time but introduced later by retrospective amendment.

In the present facts, the amendment by introduction of Explanation ­6 to Section 9(1)(vi) of the Act took place in the year 2012 with retrospective effect from 1976. This could not be have been contemplated by the Respondent wh

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