M/S Quasar Developers Pvt. Ltd., 202, ... vs Ito, Ward-6(2), Jaipur on 8 February, 2023
Further the Full Bench of Patna High Court in case of Loknath Goenka Vs. CIT (2019)
417 ITR 521/266 Taxman 199 with reference to insertion of section 64(1)(iii) w.e.f.
01.04.1976 held that the tax liability under the said provision could be charged on the
assessee in the assessment which was to be made for that accounting year i.e. 1976-77 which
would be done in A.Y. 1977-78 as the amending act introducing a new tax liability which
came into force w.e.f. 01.04.1976 could not be given a retrospective effect and be made
applicable to assessment year 1976-77. The relevant part of the judgment reads as under:-