Held that the reliance placed by the Assessing Officer and the Commissioner (Appeals) on the retrospective amendment made in section 80HHC(3) was struck down by the Gujarat High Court, which held that in such type of substantive amendment retrospective operation could be given only if it was for the benefit of the assessee and not where it adversely affected even a small section of the assessee, and that the operation of the section could be given effect from the date of amendment and not for earlier assessment years. The decision of the Gujarat High Court was affirmed by the Supreme Court. (AY.2003-04)