2021 (6) TMI 1118

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....R O R D E R PER S.S. GODARA, J.M. This assessee's appeal for A.Y. 2013-14 arises against the Commissioner of Income Tax (Appeals) "[CIT(A)]"-1, Hyderabad's order dated 17.05..2018 passed in case no. 0046/2018-19 in proceedings u/s 143(3) of the Income Tax Act, 1961 [in short 'the Act']. Heard both the parties. Case file perused. Assessee has raised the following substantive grounds ....

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....the legislature has not only incorporated necessary amendment in Sections 36(va) as well as 43B vide Finance Act, 2021 to this effect but also the CBDT has issued Memorandum of Explanation that the same applies w.e.f. 1.4.2021 only. It is further not an issue that the foregoing legislative amendments have proposed employers' contribution/ disallowance u/s 43B as against employee's contribution u/s....