TMI Blog2014 (1) TMI 1799X X X X Extracts X X X X X X X X Extracts X X X X ..... during the year? - Held that: - this issue is covered by the order of ITAT, Cochin Bench in the case of Shri Antony D. Mundackal Vs. ACIT [2013 (12) TMI 67 - ITAT COCHIN], where it was held that sec. 40(a)(ia) of the Act, inserted by the Finance Act, 2012 with effect from 1.4,2013 is clarificatory in nature and hence the benefit of the same should be applied retrospectively - appeal restored on pr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r or amend any or all the grounds of appeal. 2. At the outset, the learned Authorized Representative has pointed out that this issue is covered by the order of ITAT, Cochin Bench in the case of Shri Antony D. Mundackal Vs. ACIT, vide ITA order No.38/Coch/2013, dated 29.11.2013 with regard to applicability of second proviso to section 40(a)(ia) of I.T. Act, wherein it was observed as under: ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... it clear that we have, in effect, rejected all the contentions of the assessee except the ground relating to applicability of the second proviso to sec. 40(a)(ia) of the Act to the year under consideration. 8. In the result, the appeal filed by the assessee is treated as partly allowed for statistical purposes. 4. Nothing contrary was brought on behalf of revenue. Facts being similar, s ..... X X X X Extracts X X X X X X X X Extracts X X X X
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