https://www.taxtmi.com/caselaws?id=330715 Section 40(a)(ia) of the Income-tax Act, inserted by the Finance (No. 2) Act, 2004 and made effective from 1 April 2005, was held inapplicable to a contractor payment made during financial year 2004-05. The analysis turned on the operative date of the disallowance provision: a taxing amendment that creates a burden is construed strictly, and ambiguity is resolved in favour of the assessee. Section 4 of the Income-tax Act did not alter that result. Accordingly, the disallowance could not be applied to the earlier year's payment. en-us Tue, 12 Jul 2016 00:00:00 +0530 Thu, 17 Nov 2016 11:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=330715 Section 40(a)(ia) of the Income-tax Act, inserted by the Finance (No. 2) Act, 2004 and made effective from 1 April 2005, was held inapplicable to a contractor payment made during financial year 2004-05. The analysis turned on the operative date of the disallowance provision: a taxing amendment that creates a burden is construed strictly, and ambiguity is resolved in favour of the assessee. Section 4 of the Income-tax Act did not alter that result. Accordingly, the disallowance could not be applied to the earlier year's payment. Case-Laws Income Tax Tue, 12 Jul 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=330715