https://www.taxtmi.com/caselaws?id=216069 Rectification under Rule 19 of the AAR Procedure Rules was held maintainable notwithstanding a later withholding-tax certificate, because the certificate under sections 195 and 197 of the Income-tax Act was provisional and its modification did not bar correction of the ruling. The earlier advance ruling was also found to contain a mistake apparent from the record: after holding that the consortium was an Association of Persons under section 2(31)(v), it could not simultaneously treat the offshore-supply receipts as not taxable in India. That inconsistency was rectifiable, and the taxability of the offshore-supply income in the hands of the Association of Persons was reopened for fresh decision. en-us Mon, 27 Aug 2012 00:00:00 +0530 Sat, 16 Feb 2013 10:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=216069 Rectification under Rule 19 of the AAR Procedure Rules was held maintainable notwithstanding a later withholding-tax certificate, because the certificate under sections 195 and 197 of the Income-tax Act was provisional and its modification did not bar correction of the ruling. The earlier advance ruling was also found to contain a mistake apparent from the record: after holding that the consortium was an Association of Persons under section 2(31)(v), it could not simultaneously treat the offshore-supply receipts as not taxable in India. That inconsistency was rectifiable, and the taxability of the offshore-supply income in the hands of the Association of Persons was reopened for fresh decision. Case-Laws Income Tax Mon, 27 Aug 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=216069