Applicability of administrative circulars: earlier tax circular ceases to apply after a higher-court overruling, altering assessment year treatment. The circular issued following the earlier Cloth Traders decision ceases to have applicability for any assessment year consequent to the later Supreme Court overruling in Distributors (Baroda), which supplies the controlling legal position for tax assessments and administration.
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Applicability of administrative circulars: earlier tax circular ceases to apply after a higher-court overruling, altering assessment year treatment.
The circular issued following the earlier Cloth Traders decision ceases to have applicability for any assessment year consequent to the later Supreme Court overruling in Distributors (Baroda), which supplies the controlling legal position for tax assessments and administration.
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