2014 (1) TMI 1721

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..... f the Tribunal of 29.07.2013 rejecting its appeal. The question of law sought to be urged is with respect to the Tribunal?s interpretation of the third proviso to sub- section 3(c)(ii) of Section 80HHC.  In the present case, the return of income was processed under Section 143(1) on 12.02.2001 for the assessment year 2000-01. The assessee had claimed Rs. 3,96,90,522/- in terms of the then ex .....

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..... e the retrospectivity attached to the amendment in question.  This Court is of the opinion that having regard to the circumstances of the case, the AO could not have reopened the assessment for the year 2000-01 on the basis of the retrospective amendment, when the retrospectivity has been struck down and the amendment having been held to be prospective, i.e. from the assessment year 2005-06, .....

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