https://www.taxtmi.com/caselaws?id=275812 The second proviso to section 40(a)(ia) was treated as curative and beneficial, so it was applied retrospectively where the resident payee had already reported the income and the payer was not an assessee in default under section 201(1). Faced with conflicting High Court views, the interpretation favourable to the assessee was preferred. On that basis, the disallowance was held unsustainable and the relief granted to the assessee was upheld. en-us Fri, 26 May 2017 00:00:00 +0530 Thu, 18 Oct 2018 07:32:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=275812 The second proviso to section 40(a)(ia) was treated as curative and beneficial, so it was applied retrospectively where the resident payee had already reported the income and the payer was not an assessee in default under section 201(1). Faced with conflicting High Court views, the interpretation favourable to the assessee was preferred. On that basis, the disallowance was held unsustainable and the relief granted to the assessee was upheld. Case-Laws Income Tax Fri, 26 May 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=275812