Tax Liability u/s 64(1)(iii) Applies Only If Present at Income Accrual, Not Retrospectively.

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....Scope and applicability of Section 64(1)(iii) w.e.f. 1.4.1976 - from the date mention of that FY OR AY - liability can only be fastened on an individual if the same was existing at the time of accrual and not at the time of assessment and new liability under the IT Act cannot be given a retrospective effect - applicable in FY 1976-77 i.e AY 1977-78 not in AY 1976-77....