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TMI Blog2019 (4) TMI 1889X X X X Extracts X X X X X X X X Extracts X X X X ..... 15 to section 40(a)(ia) which has been held to be curative in nature and hence, retrospective - HELD THAT:- As pursuant to the Tribunal s direction the AO after examining the veracity of the vouchers submitted by the assessee against the payments made to various persons found out that payments have been made without deducting TDS and has found that there is no credence of the vouchers produced by ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is directed to give relief in accordance to law as per the aforesaid direction. - Shri A. T. Varkey, JM For the Appellant: Shri S. M. Surana, Advocate For the Respondent: Shri Raja Sengupta, JCIT, Sr. DR ORDER Shri A.T.Varkey, JM This appeal filed by the assessee against the order of Ld. CIT(A)-13, Kolkata dated 16.08.2018 for AY 2006-07. 2. The main grievance of the assessee in this appeal is a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... se of DCIT Vs. Punjab Infrastructure Development Board Ltd., ITA No. 774/Chd/2013 dated 30.09.2015. The Ld. DR objected to the relief prayed by the assessee, and according to him, the amendment is only w.e.f. 01.04.2015 and can be only prospective and, therefore, the disallowance should be sustained. 5. Having heard the rival submissions and gone through the facts and circumstances of the case it ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s held in the case of Punjab Infrastructure Development Board Ltd. (supra) that though the aforesaid amendment has been brought w.e.f. 01.04.2015 it is curative in nature and so retrospective in operation and so following the ratio laid by the coordinate Bench of this Tribunal, I am inclined to allow the said prayer of the Ld. AR of the assessee, therefore, I restrict the disallowance to 30% of &# ..... X X X X Extracts X X X X X X X X Extracts X X X X
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