COMMISSIONER OF INCOME TAX Vs. S. M. ANAND

JUDGEMENT

(1.) This income tax appeal is filed by the Revenue under Section 260A of the Income Tax Act, 1961 ('the Act' for short) assailing the order of the Hon'ble Income Tax Appellate Tribunal, Bengaluru Bench "B", Bengaluru in ITA No.1831/Bang/2013 dated 21.02.2014 relating to the assessment year 2005-06.

(2.) The substantial question of law that arises for our consideration is ;-

(3.) Learned counsel for the appellant-revenue would submit that in view of the specific date prescribed for giving effect to the second proviso of Section 40(a)(ia) of the Act from 01.04.2013, no other interpretation is permissible to give retrospective effect, contrary to the intention of the legislature. Reliance is placed on the following judgements: