Advance ruling on structural glazing works binds only the specific contract ruled upon, leaving other works open to assessment.

An advance ruling may determine whether a specified works contract, such as structural glazing or curtain wall installation, falls within a particular tax entry under the Karnataka Value Added Tax Act. The Commissioner could not set aside the ruling for want of jurisdiction merely because it was confined to the taxability of that identified contract. The ruling bound the assessing authority only for the specific works contract covered by it and did not extend to all other works undertaken by the taxpayer. Independent assessment of other contracts remained permissible.

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Issues: (i) Whether the Advance Ruling Authority could clarify the taxability of the appellant's structural glazing works under Entry 4 of the Sixth Schedule to the Karnataka Value Added Tax Act, 2003. (ii) Whether the Commissioner was justified in setting aside the advance ruling on the ground of want of jurisdiction. (iii) Whether the advance ruling would bind the assessing authority in respect of all works undertaken by the appellant.

Issue (i): Whether the Advance Ruling Authority could clarify the taxability of the appellant's structural glazing works under Entry 4 of the Sixth Schedule to the Karnataka Value Added Tax Act, 2003.

Analysis: The clarification sought was confined to the rate of tax applicable to a specified works contract involving fabrication, supply and installation of structural glazing works commonly known as curtain walls. An advance ruling may determine whether a particular nature of contract falls within a particular entry in the schedule.

Conclusion: Yes. The Advance Ruling Authority could validly clarify whether the specified works contract fell within Entry 4.

Issue (ii): Whether the Commissioner was justified in setting aside the advance ruling on the ground of want of jurisdiction.

Analysis: The advance ruling did not purport to extend to all past, present and future transactions of the appellant. It addressed only the nature of the specified structural glazing works. On that basis, the jurisdictional objection was not accepted.

Conclusion: No. The Commissioner was not justified in treating the ruling as beyond jurisdiction on that basis.

Issue (iii): Whether the advance ruling would bind the assessing authority in respect of all works undertaken by the appellant.

Analysis: The ruling would bind the assessing authority only to the extent of the specific structural glazing works covered by it. If the appellant undertook other kinds of work under different contracts, the assessing authority could examine whether those works independently fell within Entry 4 and exclude any work outside its scope.

Conclusion: No. The ruling was binding only for the specified works contract and not for all works undertaken by the appellant.

Final Conclusion: The advance ruling on the specified structural glazing works was upheld, while the assessing authority's power to assess other works independently was preserved.

Ratio Decidendi: An advance ruling binds the assessing authority only to the extent of the specific transaction or class of transaction ruled upon, and it does not preclude independent assessment of other contracts or works outside that ruling's scope.

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