Prospective application of section 50C safe harbour tolerance bars retrospective relief for earlier assessment years.

The amended section 50C safe harbour tolerance was held to apply only prospectively from Assessment Year 2021-22 because the legislature fixed a specific commencement date and did not express retrospective operation. The Tribunal declined to treat the higher tolerance as a curative amendment for earlier years, so it could not be applied to Assessment Year 2020-21. The assessee's challenge to the section 50C addition therefore failed.

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Issues: Whether the amended safe harbour tolerance under section 50C could be applied retrospectively to Assessment Year 2020-21.

Analysis: The increased tolerance was introduced from Assessment Year 2021-22 onwards. The amendment was not expressed to operate retrospectively, and the presence of a specific effective date indicated legislative intent to apply it prospectively only. In the absence of express retrospective operation, the Tribunal declined to enlarge the scope of the amendment by treating it as curative for prior years.

Conclusion: The amended safe harbour limit could not be applied to Assessment Year 2020-21, and the assessee's challenge to the section 50C addition failed.

Ratio Decidendi: A statutory amendment introducing a concession or tolerance is prospective where the legislature fixes a specific commencement date and does not expressly provide retrospective operation.

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