Advance ruling interpretation applies from the entry's commencement; prospective limitation on taxability of railway batteries was unsustainable.

The Tribunal held that once the Commissioner, acting under the advance ruling provision, interprets a statutory entry and determines that railway carriage batteries fall within that entry as parts of railway coaches and engines, that interpretation applies from the date the entry came into force. A statutory entry cannot be given one meaning before the ruling and another after it. The Commissioner had no authority under the West Bengal Value Added Tax Act, 2003 to restrict the ruling to prospective operation only. The Tribunal distinguished the earlier regime under the West Bengal Sales Tax Act, 1994, and set aside the rider limiting the decision's effect prospectively.

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Issues: Whether the Commissioner, while determining the taxability and rate applicable to railway carriage batteries as parts of railway coaches and engines under the advance ruling provision, could restrict the effect of that determination to operate prospectively only.

Analysis: The Tribunal held that once the Commissioner interprets the scope of a statutory entry and decides that the goods fall within that entry, the interpretation attaches to the entry from the date on which the entry itself came into force. A statutory entry cannot bear one meaning before the ruling and another meaning after it. The Commissioner, having exercised jurisdiction under section 102 of the West Bengal Value Added Tax Act, 2003, had no authority to alter the temporal operation of the statutory provision or to confine the ruling to future effect. The Tribunal also distinguished the earlier regime under section 102A of the West Bengal Sales Tax Act, 1994, and rejected the contention that the advance ruling under the 2003 Act was necessarily prospective.

Conclusion: The rider limiting the Commissioner's decision to prospective operation was unsustainable and was set aside. The assessee succeeded.

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