CBIC Clarificatory Circular Operates retrospectively & not Bring Anything New

Sanjib Das Vs The Union of India (Gauhati High Court)

First this Court would like to deal with the question as to whether the Circular dated 11.11.2021 is clarificatory in nature thereby clarifying the Master Circular No.1053/02/2017-CX dated 10.03.2017.

A Perusal of the said Circular dated 11.11.2021 stipulates that the concept of pre-show cause notice consultation in Central Excise and Service Tax was introduced vide the Board’s instructions da

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