Dismissing the appeal of the revenue the Court held that the Tribunal is right in holding that, recipients of the interest income had included the income in their return and paid taxes thereon. No disallowance can be made. Second proviso inserted by Finance Act 2012 is retrospective effect. (AY. 2012-13)
PCIT v. Mobisoft Telesolutions Pvt. Ltd. (2019) 411 ITR 607 (P&H)(HC)
S. 40(a)(ia) : Amounts not deductible-Deduction at source– Recipients of the interest income had included the income in their return and paid taxes thereon-No disallowance can be made- Second proviso inserted by Finance Act 2012 is retrospective effect. [S. 201(1)]