Advance ruling procedure: grounds for rejection and certainty on hearings, rulings, and transmission to tax officials. Procedure requires the Board for Advance Rulings to forward applications to the Principal Commissioner or Commissioner and may call for relevant records; after examination the Board may allow or reject the application. Grounds for rejection include questions pending before tax authorities or appellate bodies (with specified resident exceptions), matters involving determination of fair market value, or transactions prima facie designed for tax avoidance (subject to exceptions). Rejection requires an opportunity to be heard and reasons in the order. If allowed, the Board must pronounce a written advance ruling within six months, after considering further material and, on request, providing a hearing or representation; rulings must be signed, certified, and copies sent to the applicant and the Principal Commissioner or 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 procedure: grounds for rejection and certainty on hearings, rulings, and transmission to tax officials.
Procedure requires the Board for Advance Rulings to forward applications to the Principal Commissioner or Commissioner and may call for relevant records; after examination the Board may allow or reject the application. Grounds for rejection include questions pending before tax authorities or appellate bodies (with specified resident exceptions), matters involving determination of fair market value, or transactions prima facie designed for tax avoidance (subject to exceptions). Rejection requires an opportunity to be heard and reasons in the order. If allowed, the Board must pronounce a written advance ruling within six months, after considering further material and, on request, providing a hearing or representation; rulings must be signed, certified, and copies sent to the applicant and the Principal Commissioner or Commissioner.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
TaxTMI 
