Advance Ruling to be void in certain circumstances [Section 104]

Advance rulings obtained by fraud void ab initio, with exclusion of the ruling period from adjudication limitation.

Advance rulings obtained by fraud, suppression of material facts, or misrepresentation may be declared void ab initio by the Authority or Appellate Authority; the applicant must be given an opportunity to be heard and a copy of the voiding order must be sent to the applicant, the concerned officer and the jurisdictional officer. The period from the advance ruling to the voiding order is excluded when computing limitation for issuance of show-cause notices and adjudication orders, thereby providing authorities additional time to pursue recovery and adjudication as if no ruling had been made.