Advance ruling jurisdiction cannot be expanded through reconsideration to decide new questions or non-applicant tax liability.

The Authority for Advance Rulings' jurisdiction is limited to the questions specifically framed in the advance ruling application, and it cannot use Rule 19 to reopen a concluded ruling or enlarge the reference to new issues. Questions not originally raised cannot be introduced later, and the Authority cannot determine hypothetical tax liability of a person other than the applicant, including an association of persons. On that basis, the Revenue's attempt to revisit the ruling and raise fresh questions was rejected.

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Issues: Whether the Authority for Advance Rulings could, on an application under Rule 19, reopen the earlier ruling and determine new questions not originally framed, including the taxability of the offshore supplies in the hands of an association of persons.

Analysis: The jurisdiction of the Authority under Section 245N is confined to determining the question of law or fact specified in the application in relation to the transaction undertaken or proposed to be undertaken by the non-resident applicant. The questions originally framed for advance ruling could not be modified after the ruling had been rendered so as to introduce a different legal issue. An application under Rule 19 could not be used to reframe the reference or enlarge the scope of adjudication. The Authority was also not competent to decide hypothetical tax liability of a person other than the applicant.

Conclusion: The Authority could not reopen or decide the new issues raised by the Revenue, and the objection to such reconsideration was rejected.

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