Home Case Index All Cases Income Tax Income Tax + HC Income Tax - 2023 (6) TMI HC This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2023 (6) TMI 742 - MADHYA PRADESH HIGH COURTSubstantial question of law - retrospectivity of the amendment made to Section 23(b) of the Finance Act, 2017, the ground of deduction of overdue interest qua the ideal guidelines has not been considered by the Tribunal in its true perspective - HELD THAT:- The facts reveal that the Tribunal was seized of three set of appeals filed by the Revenue and two pro-subjections by the assessee in respect of three assessment years i.e. 2009-2010, 2013-2014 and 2014- 2015. The aspect regarding retrospectivity was not of Section 43-D of the Finance Act, 2017, it seems from the record that the Tribunal has applied its mind to the ground raised by the appellants while the other ground of deduction of overdue interest qua RBI guidelines is also discussed. Tribunal has taken care to discuss all the issues raised before it and has rendered findings which is based primarily on facts. References may have been made of certain legal provisions but the adjudication and rendering of findings are essentially facts-centric. It is settled principle of law that an appeal before this Court u/s 260-A of the Act can be entertained only and any substantial question of law as involved which does not appears to be the case herein.
|