Proviso to sec. 44BB ruling out applicability of provision in cases where sec. 44DA applies has pros

IT/ILT : Insertion of the words "section 44DA" in the proviso to section 44BB(1) by the Finance Act,2010 w.e.f.1-4-2011 is prospective and not retrospective. Amendment cannot be held to be retrospective particularly because it brings substantial change in the taxability of the assessee