Provisions of section 40(a)(ia) of Income Tax Act constitutionally valid

RELEVANT PARAGRAPH 47. As the challenge in all these writ petitions is to the vires of Section 40(a)(ia) of the Act, it will be appropriate to extract the provision as it stood as on the date of the challenge: “Section 40. Notwithstanding anything to the contrary in sections 30 to 38, the following amounts shall not be deducted in computing the income chargeable under the head “Profits and gains of business or profession- (a) in the case of an assessee- (i)….. (A)….. (B)….. (ia) any interest, commission or brokerage, rent, royalty, fees for profes...