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Commissioner Of Income-Tax vs B.M. Edward, India Sea Foods on 26 February, 1979

6. The learned counsel for petitioner is right in his contention that normally instructions/circulars applicable or in force on the first date of the assessment year should be applied, unless there are good reasons or the intendment to the contrary is so stipulated or can be clearly implied. Circular/instructions issued under Section 119 of the Act are primarily to serve guidelines and are binding on the subordinate authorities visited with administration of the Act. Sometimes a circular confers rights and benefits on the assessee with reference to W.P.(C) 8441/2007 Page 4 of 9 assessment/taxation. The board certainly has right to withdraw or recall the circular, but normally the circulars prejudicially affecting the rights of the parties should not be withdrawn or recalled with retrospective effect. (see BASF (India) Ltd. And Another v. W. Hasan, Commissioner of Income-Tax And Others [2006] 280 ITR 136 (Bom), Commissioner of Income- Tax v. B.M. Edward, India Sea Foods [1979] 119 ITR 334 (Kerala), Commissioner of Income Tax v. N.T. Ramarao (H.U.F.) [1984] 163 ITR 453 (AP).).
Kerala High Court Cites 21 - Cited by 54 - V B Eradi - Full Document

Basf (India) Ltd. And Anr. vs W. Hasan, Commissioner Of Income-Tax ... on 28 October, 2005

6. The learned counsel for petitioner is right in his contention that normally instructions/circulars applicable or in force on the first date of the assessment year should be applied, unless there are good reasons or the intendment to the contrary is so stipulated or can be clearly implied. Circular/instructions issued under Section 119 of the Act are primarily to serve guidelines and are binding on the subordinate authorities visited with administration of the Act. Sometimes a circular confers rights and benefits on the assessee with reference to W.P.(C) 8441/2007 Page 4 of 9 assessment/taxation. The board certainly has right to withdraw or recall the circular, but normally the circulars prejudicially affecting the rights of the parties should not be withdrawn or recalled with retrospective effect. (see BASF (India) Ltd. And Another v. W. Hasan, Commissioner of Income-Tax And Others [2006] 280 ITR 136 (Bom), Commissioner of Income- Tax v. B.M. Edward, India Sea Foods [1979] 119 ITR 334 (Kerala), Commissioner of Income Tax v. N.T. Ramarao (H.U.F.) [1984] 163 ITR 453 (AP).).
Bombay High Court Cites 25 - Cited by 23 - V C Daga - Full Document

Commissioner Of Income-Tax vs N.T. Ramarao (H.U.F.) on 19 November, 1984

6. The learned counsel for petitioner is right in his contention that normally instructions/circulars applicable or in force on the first date of the assessment year should be applied, unless there are good reasons or the intendment to the contrary is so stipulated or can be clearly implied. Circular/instructions issued under Section 119 of the Act are primarily to serve guidelines and are binding on the subordinate authorities visited with administration of the Act. Sometimes a circular confers rights and benefits on the assessee with reference to W.P.(C) 8441/2007 Page 4 of 9 assessment/taxation. The board certainly has right to withdraw or recall the circular, but normally the circulars prejudicially affecting the rights of the parties should not be withdrawn or recalled with retrospective effect. (see BASF (India) Ltd. And Another v. W. Hasan, Commissioner of Income-Tax And Others [2006] 280 ITR 136 (Bom), Commissioner of Income- Tax v. B.M. Edward, India Sea Foods [1979] 119 ITR 334 (Kerala), Commissioner of Income Tax v. N.T. Ramarao (H.U.F.) [1984] 163 ITR 453 (AP).).
Andhra HC (Pre-Telangana) Cites 8 - Cited by 6 - Full Document
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