Clarificatory exemption circulars operate retrospectively, extending notification benefits to lime sales under the relevant exemption scheme.

A clarificatory circular interpreting an exemption notification relates back to the date of the notification and may be applied retrospectively. On that basis, lime was held to fall within the exemption notifications covering limestone, limeshell and lime products, so the dealer could not be denied the exemption for the relevant assessment years. The Tribunal's view granting the benefit on sale of lime and directing recomputation was therefore confirmed, and the revisions failed.

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Issues: Whether lime was covered by the exemption notifications issued for limestone, limeshell and lime products, and whether the Commissioner's circular clarifying the position operated retrospectively so as to benefit the dealer for the relevant assessment years.

Analysis: The exemption notifications were already in force for the relevant assessment years. The later circular issued by the Commissioner merely clarified the scope of the notifications and did not create a new right or impose a new restriction. A clarificatory circular is treated as relating back to the date of the notification and, therefore, operates retrospectively. On that basis, the benefit of the exemption could not be denied to the dealer in respect of sale of lime.

Conclusion: The dealer was entitled to the exemption, and the Tribunal was correct in holding that the circular supported the grant of benefit on the sale of lime.

Final Conclusion: The revisions failed, and the Tribunal's order granting exemption and directing recomputation stood confirmed.

Ratio Decidendi: A clarificatory circular interpreting an exemption notification relates back to the date of the notification and may be applied retrospectively to extend the notification's benefit.

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