2017 (8) TMI 1418

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..... is in appeal against the judgment of Income Tax Appellate Tribunal dated 2.5.2016 raising the following question for our consideration : "Whether on the facts and circumstances of the case, the Appellate Tribunal was justified in deleting the disallowance of Rs. 3,06,82,812/made by Assessing Officer by invoking the provision of section 94(7) of the Act? 2. The issue pertains to invocation of cl .....

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..... y, arising out of such transaction to the extent it does not exceed the amount of dividend or income received or receivable on such securities, shall be ignored for the purpose of computing his income chargeable to tax. In plain terms, this provision having been introduced with effect from 1.4.2005, would have the effect prospectively. In the present case, purchase and sale both were prior to 1.4. .....

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