Retrospective amendment will not attract provisions of Section 263

AI Champdany Industries Limited Vs Commissioner (Calcutta High Court) Hon’ble Supreme Court in the case of COMMISSIONER OF INCOME TAX VS. MAX INDIA LTD. 2007 295 ITR 282 (SC) had taken note of the fact that Section 80HHC had been amended eleven times and different views existed on the day, when the COMMISSIONER (therein) passed the order in the said case. That apart the Hon’ble Supreme Court also took note of the amendment which was made to the Section in 2005 with retrospective effect and held that such retrospective amendment will not attract the provisions of Section 263. This interpret...