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Whether the Tribunal was justified in law in holding that the amendment made by Finance Act, 2010 in the provisions of Section 40(a)(ia) of the Income-tax Act, 1961 is not retrospective in operation on the facts and circumstances of thecase?

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Sec. 40(a)(ia) of Income Tax Act, 1961— Business Disallowance — Amendment made by Finance Act, 2010 in Section 40(a)(ia) being curative in nature is required to be given retrospective operation- The purpose of amendment made by Finance Act, 2010 is to solve the anomalies and proviso was inserted to remedy unintended consequences and to make the provision workable and a proviso which supplies an obvious omission in the Section is required to be read into the Section to give the Section a reasonable interpretation and requires to be treated as retrospective in operation so that a reasonable interpretation can be given to the Section as a whole. - A.Y. GRAMENTS INTERNATIONAL PRIVATE LTD. V/s DEPUTY CIT - [2020] 426 ITR 495 (KARN)