Advance ruling voidability: rulings obtained by fraud may be treated as never made, restoring ordinary tax law application. The Authority may declare an advance ruling void ab initio if obtained by fraud or misrepresentation; upon such declaration the Code applies to the applicant as if the ruling had never been made, excluding the period between the ruling's date and the date of the Authority's order, and a copy of the order is sent to the applicant and the Commissioner.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Advance ruling voidability: rulings obtained by fraud may be treated as never made, restoring ordinary tax law application.
The Authority may declare an advance ruling void ab initio if obtained by fraud or misrepresentation; upon such declaration the Code applies to the applicant as if the ruling had never been made, excluding the period between the ruling's date and the date of the Authority's order, and a copy of the order is sent to the applicant and the Commissioner.
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