TMI Blog2021 (6) TMI 1118X X X X Extracts X X X X X X X X Extracts X X X X ..... lso the CBDT has issued Memorandum of Explanation that the same applies w.e.f. 1.4.2021 only. It is further not an issue that the foregoing legislative amendments have proposed employers contribution/ disallowance u/s 43B as against employee s contribution u/s 36 (va) of the Act; respectively. However, keeping in mind the fact that the same has been clarified to be applicable only with prospectiv ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... This assessee s appeal for A.Y. 2013-14 arises against the Commissioner of Income Tax (Appeals) [CIT(A)] -1, Hyderabad s order dated 17.05..2018 passed in case no. 0046/2018-19 in proceedings u/s 143(3) of the Income Tax Act, 1961 [in short the Act ]. Heard both the parties. Case file perused. Assessee has raised the following substantive grounds in its appeal. 2. The ld.CIT(A)-1 fai ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mendment in Sections 36(va) as well as 43B vide Finance Act, 2021 to this effect but also the CBDT has issued Memorandum of Explanation that the same applies w.e.f. 1.4.2021 only. It is further not an issue that the foregoing legislative amendments have proposed employers contribution/ disallowance u/s 43B as against employee s contribution u/s 36 (va) of the Act; respectively. However, keeping i ..... X X X X Extracts X X X X X X X X Extracts X X X X
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