2016 (1) TMI 1025

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....very same order of the Ld. CIT(A)-13, Mumbai dated 3.03.2014 pertaining to Assessment years 2010-11 & 2011-12. Since the First Appellate Authority has disposed of these appeals by a consolidated order and as the grievance of the Revenue is identical in both these years, these appeals were heard together and are disposed of by this consolidated order for the sake of convenience. 2. The common grie....

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.... the orders of the authorities below. In our considered opinion, the dispute with regard to the nature of payment made for purchase of software was settled at rest only by Finance Act 2012 through which Explanation-4 was added to Sec. 9(1)(vii). Although the said amendment was given retrospective effect, legal maxim, lex non cogit ad impossibillia, meaning thereby that the law cannot possibly comp....