Clarificatory Board circular on scored-out M.R.P. applies to past cases and cannot be confined to prospective operation.

A Board circular clarifying the treatment of scored-out M.R.P. was treated as a clarification of the existing legal position, not an amendment in law. On that basis, its effect was not limited to future cases, and the lower appellate authority was found wrong to confine it to prospective operation only. The clarification was applied to the assessee, who was held entitled to its benefit.

---

---

Issues: Whether the Board circular clarifying the treatment of scored-out M.R.P. was applicable to the assessee's case and whether it could be denied on the ground of prospective operation only.

Analysis: The circular was treated as clarifying the existing legal position and not as effecting any amendment in law. Since it merely explained the law, the position was held to remain the same before and after the circular, and the lower appellate authority was found incorrect in restricting its application to prospective cases only.

Conclusion: The circular was held applicable to the assessee, and the assessee was held entitled to the benefit of the clarification.

---