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Issues: Whether the advance ruling application was maintainable when the transaction in question had already been completed before the date of filing.
Analysis: The application under the advance ruling provisions is confined to matters relating to supply of goods or services being undertaken or proposed to be undertaken. The consideration had already been received and, applying the statutory rules on time of supply of services, the subject transaction was found to have been completed before the filing of the application. Since the question referred to a past and completed supply, it did not satisfy the statutory precondition for a ruling.
Conclusion: The application was not maintainable and was rejected.