Reassessment u/s 147 - Applicability of Advance Rulings in the ...

Income Tax

July 21, 2023

Reassessment u/s 147 - Applicability of Advance Rulings in the own case of assessee or Advance Rulings in case of any other assessee - In view of the clear mandate of Section 245-S of the Act that a ruling would apply and be binding only on the Applicant and the Revenue in relation to the transaction for which it so sought, it is clearly evident that the Assessing Officer has ignored this clear mandate. The ruling in Cyril E. Pereira (supra) cannot as a matter of plain intendment and meaning of Section 245-S of the Act displace the binding character of the ruling rendered between Petitioner and the Revenue. - HC

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