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2002 (4) TMI 16 - HC - Income Tax"1. Whether, Tribunal is correct in holding that the amended provisions of section 40A(3) is not applicable to the facts of the case and that the entire amount added has to be sustained and not only 20 per cent. of the amount paid? - 2. Whether on the facts and in the circumstances of the case, the Appellate Tribunal was right in holding that the amendment to the provisions of section 40A(3) is not a procedural one but a substantive one?" - Tribunal was right in holding that the amended provision was only prospective. We agree with the order of the Tribunal in that behalf.
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