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2018 (5) TMI 1631 - AT - Income TaxDisallowance u/s 40(a)(ia) made on account of non-deduction of TDS on interest payment - Held that:- amended provision of Sec 40(a)(ia) should be interpreted liberally and equitable and applies retrospectively, w.e.f. AY 2005-06 so that an assessee should not suffer unintended and deleterious consequences beyond what the object and purpose of the provision mandates - since the amendment was curative in nature, it should be given retrospective effect - assessee has filed its returns on 01.08.2005 in accordance with the due date u/s 139 - hence is allowed to claim the benefit of the amendment - decided in favor of assessee.
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