Advance ruling binding effect binds the applicant and tax authorities for that transaction unless law or facts change. An advance ruling under section 245R is binding on the applicant, on the specific transaction for which it was sought, and on the Principal Commissioner or Commissioner and subordinate income-tax authorities in respect of that applicant and transaction. The binding effect does not apply if there is a change in the law or facts underlying the ruling, and the Central Government may, by notification, exclude the section's application to advance rulings pronounced on or after specified dates.