Retrospective or prospective applicability of a provision cannot be decided simply on the basis of the view taken by CBDT ignoring the plain statutory language

iPolicy Network (P) Ltd. v ITO ITAT, Delhi IT Appeal No. 5504 (Delhi) of 2010 Assessment Year 2006-07 Decided on: 17 June 2011  Order I.P. Bansal, JM 1. This is an appeal filed by the assessee under the provisions of section 253(1)(d) of the Incometax Act, 1961, against the order passed by the Assessing Officer dated 13-10-2010 under section 143(3) read with section 144C of the Income-tax Act, 1961 (the Act). 2. The main ground raised is that the Assessing Officer has erred on facts and in law in proposing to complete the assessment under section 144C/143(3) of the Income-ta...