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2001 (10) TMI 616 - CEGAT, NEW DELHIExtract: ....... valid arguments have been advanced by the appellants. As rightly pointed out by the DR, in the above circumstances, I can only draw a presumption that the circular has only prospective operation, and this presumption has not been rebutted by the appellants. I, therefore, uphold the order of the Commissioner (Appeals) and reject the present appeal.
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