A notice under section 148 was challenged by the assessee. The reasons recorded stated that the assessee had not disclosed freight receipts from exporters and net freight paid to La Freightlift Pvt Ltd fell within section 194C as payment to sub-contractor and assessee failed to deduct tax in the year under consideration. Disallowance of the entire amount was made under section 40(a)(ia) of the Act. Assessee explained the AO that the freight rates from exporters were actual payment received on behalf of La Freightlift Pvt Ltd who has paid the tax amount but since the AO did not accept the explanation a writ was filed. High Court  directed the AO to re-look at the matter in light of the amendment to section 40(a)(ia) being declaratory and curative in nature would have retrospective effect from 1-4-2005. (WP Nos. 19565 of 2008 dt. 6-01-2021) (AY.2005-06)