Advance ruling procedure requires hearings and bars rulings on pending matters, valuation disputes, or tax avoidance schemes. Advance ruling procedure permits an applicant to file a prescribed application with fees and withdraw within thirty days. The Authority forwards the ... Summary
Advance ruling procedure requires hearings and bars rulings on pending matters, valuation disputes, or tax avoidance schemes.
Advance ruling procedure permits an applicant to file a prescribed application with fees and withdraw within thirty days. The Authority forwards the application to the Commissioner, may request records, and after examination and a hearing may allow or reject the application with written reasons. Applications are barred where questions are pending before tax authorities or courts, involve fair market value determination, or concern transactions prima facie designed for income tax avoidance, subject to a notified class exception. If allowed, the Authority examines additional material, provides hearings, pronounces a written ruling and sends certified copies to the applicant and the Commissioner.
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