{"url":"https://lrlabs.ai/t/circular_23_1969_window","engine":"deterministic","llm_in_path":false,"id":"circular_23_1969_window","question":"Does Circular 23/1969's arm's-length extinguishment still apply?","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 Circular 23/1969 said arm's-length agent commission should prima facie extinguish further assessment; it was WITHDRAWN prospectively by Circular 7/2009.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Stanley (SC 2007) and Article 7 attribution, not from the circular.","pinpoint":"CBDT Circular 23 of 23 July 1969; withdrawn by Circular 7/2009","confidence":"administrative","as_at":"14 Aug 2026","quote":"If the agent's commission fully represents the value of the profit attributable to his service, it should prima facie extinguish the assessment.","quote_string_verified":true,"quote_source":"attachment:IN.ITA.S9-1-I"}