Amreli Jilla Madhyasth Sahakari Bank ... vs The Dcit-Acit-2(1), Rajkot, Rajkot on 1 July, 2025
iii. Power Finance Corpn. Ltd. v. Joint Commissioner of Income Tax, Special
Range-22 [2006] 10 SOT 190 (Delhi)
"1. Section 36(1) (viii) of the Income-tax Act, 1961 Financial corporation, reserve
created by -Assessment year 1997-98 - Whether amendment to section 36(1)(viii) by
Finance Act, 1997. from 1-4-1998 for availing benefit under section 36(1)(viii), is not
retrospective in operation and it shall - Held, yess Whether under pre-amended
provision requirement for claiming deduction was creation of special reserve and
9
ITA No.548 /RJT/2024 (AY : 2014-15)
Jasumatiben Lalitchandra Shah
restriction against withdrawal of special reserve cannot be read into main clause