Withdrawal of Circular no. 23 dated 23 July 1969 by CBDT is prospective in nature and will not apply to the pending cases

Recently, the Mumbai bench of the Income-tax Appellate Tribunal (the Tribunal) in the case of DDIT Vs Siemens Aktiengesellschaft (ITA No. 6133/Mum/2002, ITA No. 7589/Mum/2003) held that the withdrawal of circular no. Circular no. 23 dated 23 July 1969 and Circular No. 786 dated 7 February 2000 by Central Board of Direct Taxes (CBDT) is effective from 22 October 2009 as made applicable vide Circular No. 7 dated 22 October 2009.

Accordingly, it was held that the circular which was operational in AY 1998- 99 cannot be held to be

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