Advance ruling refused where the underlying consortium agreement was not produced, making tax consequences unsafe to determine.

The AAR declined to answer the advance ruling questions because the basic consortium agreement had not been produced. The requested tax rulings depended on understanding the rights created by the underlying consortium arrangement and the rights flowing from SLT to the applicant; without that foundational agreement, the nature and extent of the grantor's rights could not be properly assessed, and any ruling on the tax consequences would have been unsafe. The applicant was left to pursue its contentions before the Assessing Officer.

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Issues: Whether the Authority should answer the advance ruling questions when the basic consortium agreement had not been produced.

Analysis: The requested rulings depended upon understanding the rights created by the underlying consortium arrangement and the rights flowing from SLT to the applicant. Without the foundational agreement, the nature and extent of the grantor's rights could not be comprehended, and any ruling on the tax consequences would have been unsafe.

Conclusion: The Authority declined to rule on the questions and left the applicant to agitate its contentions before the Assessing Officer.

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