Dismissing the appeal of the revenue the Court held that ;The amendment to s. 40(a)(ia) by the Finance Act, 2010 w.e.f 01.04.2010 to provide that all TDS made during the previous year can be deposited with the Government by the due date of filing the return of income should be interpreted liberally and equitably and applied retrospectively from the date when s. 40(a)(ia) was inserted i.e., with effect from the AY 2005-2006 so that an assessee should not suffer unintended and deleterious consequences beyond what the object and purpose of the provision mandates. The amendment is curative in nature and should be given retrospective operation as if the amended provision existed even at the time of its insertion. i.e .from the date of insertion of the said provision w.e.f AY. 2005 -06 ( CANOS. 4339-4340 OF 2018, dt. 24.04.2018)( AY.2005 -06)