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Second proviso to section 40(a)(ia) must be read and given effect to retroactively
Case Law Details
- Case Name
- Principal CIT Vs M/S Manoj Kumar Singh (Allahabad High Court)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Courts
- All High Courts, Allahabad High Court
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Principal CIT Vs M/s. Manoj Kumar Singh (Allahabad High Court)
It is not disputed that Section 40(a)(ia) proviso is for the benefit of Assessee. When a provision has been made in fiscal statute for benefit of Assessee, in absence of any express provision or a provision which by necessary implication gives a different impression, such provision which is beneficial to Assessee must be read and given effect to retroactively.
FULL TEXT OF THE HIGH COURT ORDER / JUDGMENT
1. Heard Sri Alok Mathur, learned counsel for appellant and Sri Pradeep Agrawal, learned counsel for responde...
