Jivaram Magaji Chaudhary,, Pune vs Deputy Commissioner Of Income-Tax,, on 31 May, 2017
He, further, submitted that the Explanation 2 added to section
132B was for the purpose of removal of doubt and therefore it is
9
ITA No.1039/PUN/2015
AY.No.2011-12
retrospective in operation and therefore, the amendment made is
declaratory in nature and for this proposition, he relied on the decision of
Commissioner of Income Tax vs. Poder Cements (1997) 226 ITR
625(SC).