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2024 (3) TMI 478 - AT - Income TaxDisallowance of deduction u/s 80P by way of “processing” under sub-sec.(a)(v) thereof - HELD THAT:- Revenue could hardly dispute that such a deduction under Chapter-VIA have been made disallowable in sec. 143(1)(a)(v) “processing” vide Finance Act 2021 w.e.f. 01.04.2021 without having any retrospective effect. We are in assessment year 2018- 2019 only. This being the clinching factual and legal position, it is held that the impugned processing dated 03.09.2019 as upheld in the CIT(A)'s order, disallowing sec. 80P claim is not sustainable in law going by stricter interpretation as per Commissioner of Customs (Imports), Mumbai vs. M/s. Dilip Kumar And Co. & Ors.[2018 (7) TMI 1826 - SUPREME COURT]. Ordered accordingly.
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