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....ench of two learned judges had taken the view that the conclusion of an earlier Bench of three learned judges was difficult to accept. The issue relates to whether Explanation 2 to section 40(b) of the Income-tax Act, 1961, introduced with effect from April 1, 1985, is prospective in operation or only declaratory. In Brij Mohan Das Laxman Das v. CIT [1997] 223 ITR 825 (SC), two learned judges c....