[ compiled answer ]
law as at 14 Aug 2026 · administrative
Does Circular 23/1969's arm's-length extinguishment still apply?
The compiled answer
Only within its validity window. Circular 23/1969 said arm's-length agent commission should prima facie extinguish further assessment; it was WITHDRAWN prospectively by Circular 7/2009. For years before the withdrawal the circular binds the Revenue; for later years the same substantive result flows from Morgan Stanley (SC 2007) and Article 7 attribution, not from the circular.
Pinpoint
CBDT Circular 23 of 23 July 1969; withdrawn by Circular 7/2009
String-verified quote
“If the agent's commission fully represents the value of the profit attributable to his service, it should prima facie extinguish the assessment.”
source: attachment:IN.ITA.S9-1-I — verified at load; a quote that stops matching its source is a compile error
Computed by a deterministic engine over compiled law — no generative model in the evaluation path. JSON twin: /t/circular_23_1969_window.json · Ask with YOUR facts: GET /compute?lookup=… · MCP: POST https://lrlabs.ai/mcp (lookup_compiled_rule)