Decision of coordinate Bench of the tribunal dismissed an appeal saying that the amendment to Section 40(a)(ia) of the Act by the Finance Act (No.2) Act, 2014 was retrospective in operation and the disallowance on account of the non-deduction of TDS was liable to be restricted to 30% as against 100 made by the AO and confirmed by the ld. CIT(A). It is recalled citing the decision of the Hon’ble Supreme Court in the case of Shree Choudhary Transport Company (2020) 426 ITR 289 (SC) stating that there has been an apparent mistake in interpretation. The Tribunal held that the disallowance of 100%, by the said amendment was restricted to 30%, thus, clearly the amendment was brought in to remove the hardship caused to the assessee. The AO is directed to restrict the disallowance u/s.40(a)(ia) of the Act to 30%. (AY.  2014-2015)