((-1-)) HVN IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION INCOME TAX APPEAL NO. 35 OF 2001 The Commissioner of Income Tax ... Appellant Versus M/s. KEC International Ltd. ... Respondent Mr. S.M. Shah with Mr. Sandeep Wasnik and Mr. P.S. Sahadevan for the Appellant. Mr. P.J. Pardiwala i/by Shaunak Satpute & Co. for Respondent. CORAM: F.I. CORAM: F.I. CORAM: F.I. REBELLO REBELLO REBELLO & R.S. MOHITE, JJ. R.S. MOHITE, JJ. R.S. MOHITE, JJ. DATED: JANUARY 15, 2008 DATED: JANUARY 15, 2008 DATED: JANUARY 15, 2008 P.C. P.C. P.C. . We are concerned with the assessment year 1983/84. The question of law framed is as under : "Whether on the facts and in the circumstances of the case, the Tribunal was justified in law in confirming the order of the CIT (A) and directing the A.O. to allow interest u/s. 214 of the I.T. Act as per the original assessment order?" . The appeal was preferred by the Revenue. The tribunal noted that Section 214 was substituted with ((-2-)) effect form 1.4.1985 and as per the notes of clauses, the amendment was to take effect from 1.4.85-86 and subsequent years. We are in agreement with that finding. It is therefore, clear that the amendment is prospective and did not apply to the earlier assessment years. Considering the above, the question of law would not arise. Hence, appeal dismissed. (R.S. MOHITE, J.) (R.S. MOHITE, J.) (R.S. MOHITE, J.) (F.I.REBELLO, J.) (F.I.REBELLO, J.) (F.I.REBELLO, J.)