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TMI Blog2019 (9) TMI 600X X X X Extracts X X X X X X X X Extracts X X X X ..... to Section 40(a)(ia) of the Act, which is held to be curative and hence retrospective, by the case of DCIT vs. Punjab Infrastructure Development Board Chandigarh [ 2015 (9) TMI 1663 - ITAT CHANDIGARH] D/R, had no objections with the same. We reverse the order of the CIT(A) and restore the disallowance made by the Assessing Officer u/s 40(a) (ia) of the Act, to the extent of 30% of the total ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... essee is a company and is in the business of trading. A search and seizure operation was conducted on the Prakash Group of Companies on 21/11/2013 and on subsequent dates. A survey operation u/s 133A of the Act, was conducted in the business premises of the assessee. Notice u/s 153C of the Act, was issued on 09/12/2015, and served on the assessee on 14/12/2015. The assessee had originally filed it ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessee in their own return and they have paid tax on it. The assessee has further claimed that PAN and details tax payment have been filed before the AO. Therefore, as per the ratio decided by the Hon'ble Supreme Court in the case of Hindusthan Cocakola reported in 293 ITR assessee's claim to be allowed. 6. I have considered the finding of the AO and the written submiss ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ance may be sustained in view of the amendment brought in by the Finance Act No. 2, w.e.f. 01/04/2015 to Section 40(a)(ia) of the Act, which is held to be curative and hence retrospective, by the ITAT Chandigarh Bench of the Tribunal in the case of DCIT vs. Punjab Infrastructure Development Board Chandigarh; ITA No. 774/CHD/2013, order dt. 30/09/2015. The ld. D/R, had no objections with the sa ..... X X X X Extracts X X X X X X X X Extracts X X X X
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