https://www.taxtmi.com/caselaws?id=171955 A fiscal public notice made operative from 1-4-1999 could not be treated as a retrospective clarification to deny DEPB credit for exports completed before that date. The text applies the settled rule that retrospectivity in fiscal matters must be clearly expressed, and where the scheme is ambiguous or reasonably capable of more than one interpretation, the construction favouring the assessee prevails. Because the export had already taken place under the earlier policy, the benefit under that regime remained accrued and could not be withdrawn by the later notice. The operative effect is that completed transactions are governed by the policy in force at the time of export, not by a later prospective amendment. en-us Fri, 16 Sep 2005 00:00:00 +0530 Tue, 11 Aug 2015 13:07:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=171955 A fiscal public notice made operative from 1-4-1999 could not be treated as a retrospective clarification to deny DEPB credit for exports completed before that date. The text applies the settled rule that retrospectivity in fiscal matters must be clearly expressed, and where the scheme is ambiguous or reasonably capable of more than one interpretation, the construction favouring the assessee prevails. Because the export had already taken place under the earlier policy, the benefit under that regime remained accrued and could not be withdrawn by the later notice. The operative effect is that completed transactions are governed by the policy in force at the time of export, not by a later prospective amendment. Case-Laws Customs Fri, 16 Sep 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=171955