Retrospective amendment to section 80P narrows deduction eligibility by requiring agricultural produce to be grown by members themselves.

Retrospective amendment to section 80P(2)(a)(iii) of the Income-tax Act was treated as changing the law from 1 April 1968, requiring the agricultural produce to be grown by the members themselves. The earlier view allowing deduction where produce belonged to member societies was superseded. On that construction, marketing produce grown by members of member societies did not satisfy the statutory condition, so the deduction was unavailable. The Tribunal's interference with the revisional order was therefore not sustained.

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Issues: Whether the assessee was entitled to deduction under section 80P(2)(a)(iii) of the Income-tax Act, 1961 after the retrospective amendment requiring the agricultural produce to be grown by its members, and whether the Tribunal was right in interfering with the revisional order.

Analysis: The retrospective amendment to section 80P(2)(a)(iii) was held to alter the legal position with effect from 1 April 1968 and to supersede the earlier interpretation that permitted deduction where the produce marketed belonged to members. After the amendment, the statutory requirement was that the agricultural produce must be grown by the members, and it was not enough that it had been grown by members of member societies. Since that requirement was not satisfied, the assessee could not claim the deduction.

Conclusion: The questions were answered against the assessee and in favour of the Revenue, and the deduction under section 80P(2)(a)(iii) was held to be unavailable.

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