The assessee had claimed labour charges, Architect Fees and towards expenses under head commission, which were in nature of payments made towards contract payment u/s 194C, professional fees payment u/s 194H and commission payment u/s 194H. Assessee had also failed to deposit TDS amount so deducted from payments made towards expenses on account of labour charges, professional fees and commission to Central Govt. A/c within specified time limit. AO made disallowance u/s 40(a)(ia) of the Act.  CIT (A) confirmed the disallowance. On appeal the Tribunal held that as per amendment brought to Finance Act, 2014 in s. 40(a)(ia) w.e.f. 01.04 2015  if 100% disallowance made u/s 40(a)(ia), that would be restricted to 30% only giving retrospective effect. Intent of legislature to reduce hardship, it was proposed that in case of non-deduction or non-payment of TDS on payments made to residents as specified in s. 40(a)(ia), disallowance should be restricted to 30% of amount of expenditure claimed. (AY. 2014-15)