9911796707
TMI Blog2022 (12) TMI 574X X X X Extracts X X X X X X X X Extracts X X X X ..... Sr. D/R ORDER PER SHRI MANISH BORAD, ACCOUNTANT MEMBER: The present appeal is directed at the instance of the assessee against the order of the National Faceless Appeal Centre (hereinafter the "ld. CIT(A)") dt. 12/03/2022, passed u/s 250 of the Income Tax Act, 1961 ("the Act'), for Assessment Year 2006-07. 2. The assessee has raised the following grounds of appeal:- "1. For that the ld. CI ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the assessee referring to the decision of the Co-ordinate Bench at Rajkot in the case of Punabhai G. Pardava vs. ITO in ITA No. 219/RJT/2018, order dt. 08/06/2022, stated that in this decision, the amendment brought in by the Finance Act (No. 2) 2014 effective from 01/04/2015 made in the provisions of Section 40(a)(ia) of the Act have been held to be clarificatory in nature and, therefore, applica ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ef by the ld. CIT(A) but then the assessee approached the Tribunal which vide its order dt. 28/02/2019 in ITA No. 564/Kol/2018, remanded the matter back to the file of the Assessing Officer for denovo adjudication of the issue of disallowance u/s 40(a)(ia) of the Act amounting to Rs.2,85,500/-. Thereafter the ld. Assessing Officer completed the assessment u/s 143(3) r.w.s. 254 of the Act on 25/07/ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n the case of Neena Kual vs. Asstt. CIT [IT Appeal No. 1386 (Mum) of 2017, dated 21.05.2019] held that the amendment brought in by Finance Act No. 2 of 2014 restricting the disallowance u/s 40(a)(ia) of the Act to the tune of 30% of the expenses was made effective from 01/04/2015. But thereafter, clause 14.3. of the explanatory memorandum to Finance Bill 14 was said to be brought to effect to remo ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
