DIRECTOR OF INCOME TAX NEW DELHI vs. M/S S.R.M.B.DIARY FARMING (P) LTD

Appeals are dismissed in terms of signed reportable

Bench: HON'BLE MR. JUSTICE SANJAY KISHAN KAUL

1, dealing with the question how a beneficial circular is to be construed, has approached this question in the following manner. At paragraph 13 of the judgment, it is stated that the learned counsel further submitted that the circular being oppressive and against the respondent, has to apply only prospectively and cannot be applied retrospectively. In other words, a beneficial