Retrospective application of a later circular was rejected where it could not disturb an existing advance ruling.

A later circular could not be applied retrospectively to unsettle an advance ruling and the appellate advance ruling already passed in the taxpayer's case. The circular did not directly address the issue raised in the writ petition and was not in force when the ruling and appellate order were made. On that basis, it could not form the basis for interference with the impugned appellate order, and the plea founded on the subsequent circular was rejected.

---

---

Issues: Whether a circular issued on 03.08.2022 could be applied retrospectively to invalidate the advance ruling and the appellate advance ruling already passed in the petitioner's case.

Analysis: The later circular was found not to directly cover the issue raised in the writ petition. It was also not in existence at the time when the advance ruling and the appellate order were made. On that basis, the circular could not be treated as the foundation for interfering with the impugned appellate order.

Conclusion: The plea based on the subsequent circular was rejected and no interference with the impugned order was warranted.

---