Finance Act 2014 limits disallowance u/s 40(a)(ia) to 30% for non-deduction of TDS, applied retrospectively.

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....Disallowance u/s 40(a)(ia) - non-deduction of tax at source (TDS) - the amendment brought in by Finance Act No. 2 of 2014 restricting the disallowance u/s 40(a)(ia) of the Act to the tune of 30% of the expenses was made effective from 01/04/2015. But thereafter, clause 14.3. of the explanatory memorandum to Finance Bill 14 was said to be brought to effect to remove hardships faced by the assessee and thus, the said amendment was held to be clarificatory in nature and applicable retrospectively. - AT....