Section 40(a) (ia) of the Income Tax Act 1961 – Business disallowance – Interest,
etc paid to resident without deduction of tax at source (Second Proviso) –
Assessment Year 2006-07 – Whether insertion of second proviso to section 40(a) (ia)
with effect from 1.4.2013 is declaratory and curative in nature and it has
retrospective effect from 1.4.2005, being date from which sub clause (ia) of section
40(a) was inserted by finance (No.2).

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