also. In view of this the only issue
remains that whether amendment made by the Financial Act 2010 to
provision of section ... present case revolves around the fact that
whether the amendment made by the Finance Act, 2010 to the
provisions of Section
carried the matter before the CIT(A) who by considering the
amendment made by finance bill 2021 upheld the order of AO.
Aggrieved ... further submitted that
CIT(A) has erred in relying on the amendment made by Finance
Bill 2021. He submitted that the memorandum to the Finance
section 11 during the relevant period and it was only the
amendment made by the Finance Act, 2017 with effect from ... this section 11 , by inserting clause (ba) in
section 12A. The amendment made by the Finance Act is an
extension of the objects sought
hence, would apply retrospectively.
Without prejudice, he submitted, even if the amendment made
6
ITA No. 204/Del/2021
AY: 2011-12
would apply prospectively ... 2016 in this case is prior to
amendment unaffected by the amendment made by way of Finance
Act 2017.
12. In CIT v RRJ Securities
substance, the
learned Departmental Representative submitted that, in view of the
amendment made to Section 14A of the Act by Finance Act, 2022 ,
disallowance ... stood on that date was 30 per cent. By amendment made in the
relevant rules by the Income-tax (Fifth Amendment} Rules, 1980,
the rate
crucial issue which arises
for consideration is, whether the aforesaid amendment made to
sections 153A and 153C of the Act would apply prospectively or
retrospectively ... 2016 in this case is prior to amendment unaffected by the
amendment made by way of Finance Act 2017.
12. In CIT v RRJ Securities
Larger
Bench)]: In this case the issue involved was whether
amendment made in Explanation 4 to section 271(1)(c) by the
Finance ... this case
the issue was whether amendment made in section 139(8) by
the Taxation Laws (Amendment) Act, 1984 was retrospective
as the effective date
that as there is no saving clause
in the amendment made accordingly all the proceedings initiated and in progress
even for the period prior ... language of the
amendment itself proves the implied saving clause in the amendment because it
is specifically mentioned that the amendment will take effect from
that as there is no saving clause
in the amendment made accordingly all the proceedings initiated and in progress
even for the period prior ... language of the
amendment itself proves the implied saving clause in the amendment because it
is specifically mentioned that the amendment will take effect from
alleged
Page 3 of 50
contention that the amendment made to the said section vide Finance
Act 2009, wherein the appellant's sphere ... assessee falls into eligible business. With respect to the
amendment made in Finance Act 2009 it was stated that now the section is
eligible
