Allowing the appeal of the assessee the Court held that; prior to assessment Year 1999-2000 benefit under Section 80IA is available without exclusion of deduction Under S.80HHC .Sub –section (9A) with effect from 1-4-1999 is prospective. Circulars binding on revenue .Liberal interpretation  The amendment by introduction of sub-section 9A to section 80IA is explicitly prospective with effect from April 1, 1999 .It is neither declaratory or clarificatory nor is it in the nature of explanation. Thus , a strict reading of fiscal statute would prevent the amendment being read as retrospective in the absence of the statute providing for it .( AY.1997 -98)