Thursday, 27 June 2013

ITAT cites from Taxmann's ‘Interpretation of Statutes’; retro effect couldn’t be given to prospectiv

IT : Finance Act, 2013 inserted Explanation 2 to section 132B with effect from 1-6-2013 to clarify that existing liability shall not include advance tax liability so that cash seized during search can't be adjusted towards advance tax liability and can be adjusted only towards liability arising from completed assessments. Since legislature has by express words made Explanation 2 operative prospectively from 1-6-2013, no retrospective effect can be give to it so as to make it applicable to sear


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