2018 (1) TMI 608

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..... pondents in item nos. 12 and 14. Mr. Asheesh Jain, Senior Standing Counsel with Mr. Shahrukh Ejaz, Advocate for respondents in item no. 13.   MR. S. RAVINDRA BHAT (ORAL)   In all these cases, retrospective amendment to Sections 28 and 80 HHC of the Income Tax Act 1961 ('the Act') and the validity of CBDT Circular dated 17.1.2006 (no. 2 of 2006 ), made in the light of the amendments, h .....

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..... nature. 4. This Court notices that in the meanwhile, a Division Bench of this Court in 'Pawan Kumar Jain vs. Union of India', (2014) 46 taxmann.com 341 (Delhi) had also concluded that the amendment could not be treated as retrospective and directed further relief. In the light of these developments, the Court is of the opinion that the provisions are to be treated as prospective and not retrospec .....

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