2022 (8) TMI 758

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....dara, JM: This assessee's appeal for Assessment Year 2016-17 is directed against the Commissioner of Income Tax(Appeals)-3, Pune's order dated 12.06.2019 passed in case no.PN/CIT(A)-3/cir- 3,Pn/157/2018-19, in proceedings u/s.143(3) of the Income Tax Act, 1961 [in short "the Act"]. Heard both the parties. Case files perused. 2. Coming to assessee's sole substantive grievance challenging b....

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....in the Revenue's instant arguments as the legislature has incorporated similar tolerance margin(s) of 5 and 10% in section 50C(1), third proviso by the very Finance Act, 2020 w.e.f 01.04.2021. Case law [2021] 187 ITD 738 (Mum) Maria Fernandes Cheryl Vs. ITO holds the same as having retrospective effect since curative in nature. We wish to clarify the only difference between section 43CA and sectio....