Fraudulently obtained advance rulings may be declared void ab initio after notice, representations, and hearing opportunities for affected parties.

Advance rulings allegedly obtained by fraud or misrepresentation of facts may be examined upon a supported representation or other information. Where a prima facie case exists, the applicant must receive written notice of the grounds and relied-upon documents, with reasonable opportunities for written representation and hearing. The concerned Principal Commissioner or Commissioner must also receive the notice and may comment and be heard. On finding that fraud or misrepresentation procured the ruling, the Authority shall declare it void ab initio.

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