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Whether, on the facts and circumstances of the case, the Income-tax Appellate Tribunal was right in holding that amendment made to section 40(a)(ia) by Finance Act, 2010 would apply retrospectively though the amendment is made with effect from 1-4-2010 ?

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Section 40(a)(ia) of the Income-tax Act, 1961—Business disallowance— Amended provision of section 40(a)(ia) should be interpreted liberally and equitable and applies retrospectively from the date when section 40(a)(ia) was inserted i.e., with effect from the Assessment Year 2005-06 so that an assessee should not suffer unintended and deleterious consequences beyond what the object and purpose of the provision mandates. - CIT V/s ARCHEAN GRANITES (P.) LTD. - [2020] 273 TAXMAN 511 (MAD)