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2007 (8) TMI 333 - MADRAS HIGH COURTScheme to help revive sick companies - Both the CIT (A) and the ITAT placing reliance on Circular No. 523, dated October 5, 1988, found that the assessee was entitled to the benefit of carry forward loss of the earlier years – circulars in the nature of concession can be withdrawn prospectively only - In the subsequent Circular no. 683 dated June 8, 1994, the CBDT had only laid a new procedure for extension of benefit - Such a procedure could always be prospective operation only – assessee is entitled to benefit under earlier scheme – revenue appeal dismissed
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