2021 (6) TMI 1059

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..... necessary amendments in Sections 36(va) as well as 43B vide Finance Act, 2021 to this effect but also the CBDT has issued Memorandum of Explanation that the same applies w.e.f. 1.4.2021 only. It is further not an issue that the forergoing legislative amendments have proposed employers contributions; disallowances u/s 43B as against employee u/s 36 (va) of the Act; respectively. See M/S MERCHEM LIM .....

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..... sessee s appeal for A.Y. 2019-20 arises against the Commissioner of Income Tax (Appeals) [CIT(A)] -3, Hyderabad s order dated 11.09.2020 passed in case no. 11120/2019-20 in proceedings u/s 143(1) of the Income Tax Act, 1961 [in short the Act ]. Heard both the parties. Case file perused. Assessee has raised the following substantive grounds in its appeal. 2. The ld.CIT(A)-3 erred in su .....

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..... ely. I notice in this factual backdrop that the legislature has not only incorporated necessary amendments in Sections 36(va) as well as 43B vide Finance Act, 2021 to this effect but also the CBDT has issued Memorandum of Explanation that the same applies w.e.f. 1.4.2021 only. It is further not an issue that the forergoing legislative amendments have proposed employers contributions; disallowances .....

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