Supreme Court rules Section 40(a)(ia) amendment inapplicable for consistent TDS defaults; appellant denied 2014 amendment benefits.

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....Effect of amendment to section 40(a)(ia) - Failure to deduct / deposit TDS - Amendment made is effective from 1.4.2005 means it is effective from AY 2005-06 (i.e. FY 2004-05) - Further, the appellant had not been a bonafide assessee who had made the deduction and deposited it subsequently. Obviously, the appellant could not have derived the benefits that were otherwise available by the curative amendments of 2008 and 2010. Having defaulted at every stage, the attempt on the part of assessee-appellant to seek some succor in the amendment of Section 40(a)(ia) of the Act by the Finance (No.2) Act, 2014 could only be rejected as entirely baseless, rather preposterous.- SC....