Every statute is prima facie prospective unless it is expressly or by necessary implication made to have retrospective operation. There is a presumption of prospectivity of a statute. Whether machinery have retrospective effect ,depends on content and nature of provisions of a taxing statute have to give effect to its manifest purposes.
CIT v. Essar Teleholdings Ltd. (2018) 401 ITR 445 (SC) (HC)
Interpretation of taxing statutes — Presumption of prospectivity of statute- Machinery provisions .