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Section 40(a)(ia) of the Income Tax Act, 1961— Business Disallowance — Second proviso to section 40(a)(ia) inserted by the Finance Act, 2012 is declaratory and curative in nature and it has retrospective effect from 1st April, 2005 being the date from which sub clause(ia) of section 40 (a) was inserted — Commissioner of income tax vs. SM Anand [2019] 311 CTR (Karnataka) 795