Allowing the petition the Court held that clause (viii) of the Department circular in F. No. 299/10/2022-Dir (Inv. III)/611, dated August 1, 2022 provides that if an assessee requests for a personal hearing, the same may be dealt with following the principles of natural justice by giving a reasonable period for compliance of notice specifying the date of hearing. The circular is binding. Even though the clarification dated November 9, 1989 was executive in nature, the concessions given to the assessee could be withdrawn only prospectively, but not retrospectively because, such executive circulars are binding on the authorities. Order was set aside. (AY.2016-17)