engaged only in the
distribution of electricity. He referred to the amendment made in Section
32(1)(iia) by the Finance Act, 2012 whereby ... depreciation subsequently with effect from 1st April
2017 as per the amendment made again by the Finance Act, 2016 in the
provision of Section
that now in any case with the retrospective
amendment made by Parliament to Section 36(1)(va) and 43B of the 1961 Act
wherein Explanation ... second proviso and further amendment in the first proviso, quoted above.
By the Finance Act, 2003 , the amendment made in the first proviso
equated
urged that by virtue of the Finance Act, 2018 , the only amendment
made in Section 45(1) PMLA is that the term "punishable ... PMLA do not stand revived by virtue of the
amendment made in 2018.
(R) Reference was made to the decisions in M/s Ujagar Prints
provisions under Section 24 and Section 210 consequent to the amendment made in terms of the U.P. Act No. 4 of 2016, stood ... post the amendment, would have to be considered in juxtaposition, as follows :-
Pre-amendment
Post-amendment
Section 24 (4) .─Any person aggrieved by the order
levied on the Composite Works Contracts
pursuant to the Finance Act amendment made vide Finance Act, 2007 .
However, for the reasons to be recorded hereinbelow ... levy of
service tax on composite works contract prior to the amendment made
to the Finance Act, 1994 in the year 2007 by which Section
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
averred that by virtue of the Finance Act, 2018 , the only
amendment made in Section 45(1) PMLA is that the term "punishable ... PMLA post the decision in
Nikesh Tarachand Shah (Supra) and the amendment made in the provision
by virtue of Finance Act, 2018 , has held that
received any dividend for 3
consecutive years. As per the amendment made, X was subjected to Section
14A disallowance for the expenditure incurred. X then ... made taxable should
also be made applicable retrospectively, and thus no disallowance of
expenditure would be warranted.
Further, the amendment has been made effective from
Relevant PB 72
4 Madras NLC Indcoserve v. ITO Index-I, Amendment made
Bench {2022 (6) TMI 936 dated by Finance ... referred
Relevant PB 97
5 Raipur Gramin Seva Sahakari Index-I, Amendment made
Bench Samiti Maryadit v. ITO by Finance
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
