JUDGMENT Order appellant-assessee herein is engaged in production and distribution of motion pictures mainly in Tamil language. There was search under section 132 of Income-tax Act, 1961 (hereinafter referred to as "the Act") at business premises of assessee during which certain books of account were seized. Consequent to search, proposal was made for assessment for block period of ten years April 1, 1986, to March 31, 1996, and thereafter up to September 13, 1996. Assessing Officer disallowed expenditures where payments were made in cash in excess of Rs. 10,000 relying on section 40A(3) of Act as it stood prior to April 1, 1996. appellant filed appeal before Income-tax Appellate Tribunal, Madras Bench (for short "the Tribunal"). Tribunal, vide order dated June 28, 2000, partly allowed appeal and remitted matter to Assessing Officer for considering claim whether income/loss from file Thirumurthy was to be computed for assessment year 1996-97 in accordance with rule 9A of Income-tax Rules. It was also directed that in making computation Assessing Officer will consider expenditure and make disallowance under provisions of section 40A(3) of Act, as was applicable for assessment year in question. Feeling aggrieved by order of Appellate Tribunal, appellant filed appeal before High Court. High Court did not accept contentions of appellant which were based on amended section 158B(b) in Chapter XIV-B by Finance Act, 2002, and dismissed appeal. Questioning validity of aforesaid judgment of High Court, present appeal has been preferred with leave of court. As is clear from facts noted above, because of search carried on at premises of appellant-assessee, proposal was made for completion of assessment for block period of ten years from April 1, 1986, to March 31, 1996. In year 1996, provisions of section 40A(3) of Act did not allow any expenditure if it was more than Rs. 20,000 and paid in cash. only exception that was carved out in such cases where assessee could satisfactorily demonstrate to Assessing Officer that it was not possible to make payment in cheque. Even in those cases, expenditure was allowable up to Rs. 10,000, and all cash payments made in excess of Rs. 10,000 were to be disallowed as expenditure. provisions of section 40A(3) were amended with effect from April 1, 1996. With this amendment, in cases where cash payment is made in excess of Rs. 20,000, disallowance is limited to 20 per cent. of expenditure. Since date of amendment falls within aforesaid block period, assessee wants benefit of this amendment for entire block period of ten years, i.e., April 1, 1986, to March 31, 1996. Such plea is unacceptable on face of it. It is clear that amendment is substantive in nature, which is so mentioned in explanatory notes of amendments as well. Once we find that amendment is substantive in nature, it cannot be applied retrospectively. only ground on which assessee wants benefit of this amendment from April 1, 1986, is that assessment was of block period of ten years. However, on our pertinent query, learned counsel for appellant was fair in conceding that there is no judgment or any principle which would help appellant in supporting aforesaid contention. We are, thus, of opinion that order of High Court is perfectly justified. There is no merit in this appeal, and same is accordingly dismissed. *** M. G. Pictures (Madras) Ltd. v. Assistant Commissioner of Income-tax