under this anti-avoidance provision. It is a case of a
curative amendment to take care of unintended consequences of the
scheme of section ... time period only.
There is no good reason for holding the curative amendment to be
only as prospective in effect."
7. ............ The reasons assigned
time period only. There is no good reason for
holding the curative amendment to be only as prospective in effect. Dealing
with a somewhat materially ... well settled legal position to the effect that a curative
amendment to avoid unintended consequences is to be treated as
retrospective in nature even though
time period only. There is no good
reason for holding the curative amendment to be only as prospective in effect.
Dealing with a somewhat materially ... well settled legal position to the effect that a curative
amendment to avoid unintended consequences is to be treated as retrospective
in nature even though
Hence, in view of abo ve mentioned submission and
curative amendment introduced by CBDT notification 81/2023
dated 25.08.2023, addition ... CBDT notification 81/2023 date d 25.08 .2023
which is a curative amendment and the same will be applicable
7 ITA No. 8389/Del/2019
subsequent
years."
28. The controversy surrounding the above
amendment was whether the amendment being curative in
nature should be applied retrospectively i.e. from ... developments with regard to the section recorded above
show that the amendment was curative in nature, it should
be given retrospective operation
subsequent
years."
28. The controversy surrounding the above
amendment was whether the amendment being curative in
nature should be applied retrospectively i.e. from ... developments with regard to the section recorded above
show that the amendment was curative in nature, it should
be given retrospective operation
subsequent
years."
28. The controversy surrounding the above
amendment was whether the amendment being curative in
nature should be applied retrospectively i.e. from ... developments with regard to the section recorded above
show that the amendment was curative in nature, it should
be given retrospective operation
subsequent
years."
28. The controversy surrounding the above
amendment was whether the amendment being curative in
nature should be applied retrospectively i.e. from ... developments with regard to the section recorded above
show that the amendment was curative in nature, it should
be given retrospective operation
subsequent
years."
28. The controversy surrounding the above
amendment was whether the amendment being curative in
nature should be applied retrospectively i.e. from ... developments with regard to the section recorded above
show that the amendment was curative in nature, it should
be given retrospective operation
subsequent
years."
28. The controversy surrounding the above
amendment was whether the amendment being curative in
nature should be applied retrospectively i.e. from ... developments with regard to the section recorded above
show that the amendment was curative in nature, it should
be given retrospective operation
