ITAT Deletes Rs. 90.70 Crore Adjustment Made u/s 11(3), Holds Amendment Prospective and Utilization Within Permissible Timeframe

The Income Tax Appellate Tribunal (ITAT) has deleted a crore adjustment, holding that the amendment was prospective and utilization was within the permissible timeframe. This significant ruling provides relief to the assessee, emphasizing that tax law amendments are generally prospective (apply from a future date) unless explicitly stated otherwise. The ITAT found that the adjustment was based on a retrospective application of an amendment that should not have applied to the period in question. This decision reinforces the principle of legal certainty and protects taxpayers from adverse effects of retroactive changes.