Calcutta Export - Section 40(a)(ia) curative
Facts
30% disallowance under Section 40(a)(ia) where TDS deposit was made after the financial year but before ITR due date.
Issue
Whether the 2014 amendment (allowing TDS deposit before ITR due date to avoid disallowance) is retrospective?
Held
Yes - the amendment is curative and retrospective, applicable to all pending assessments.
Ratio
Curative amendments correcting harshness are retrospective.
Use via API
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