Section 142A of the Income Tax Act is not retroactive; applies only from October 1, 2014.

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....Reference of matter to the Valuation Cell u/s 142A - There is no merit in the Department’s contention that the extant section 142A is applicable retrospectively. The section has specifically been made applicable, by the legislature itself, w.e.f. 1.10.2014 and so, it cannot be said to operate retrospectively. - AT....