Administrative rulings protect taxpayers relying on published interpretations from inconsistent assessments and penalties if reliance preceded withdrawal. The Commissioner may publish Gazette notifications ruling on interpretation or application of the Act to classes of persons or transactions, subject to restrictions, and specify an effective date. If a person implements a transaction in reliance on a published ruling that has not been withdrawn at the time and the ruling applies to that transaction, no inconsistent assessment or penalty may be raised even if the ruling is later found incorrect. Withdrawal or qualification of a ruling by Gazette notification does not affect reliance entitlement for transactions commenced or completed before such withdrawal.