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    <title>2022 (10) TMI 310 - APPELLATE AUTHORITY FOR ADVANCE RULING, GUJARAT</title>
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    <description>Where an advance ruling rests on a factual premise later shown to be incorrect, it cannot be sustained if the appeal depends on materially different facts not examined by the original authority. The appellate authority noted that the dispute over research and development services turned on whether the relevant goods were supplied by a foreign customer or manufactured in India, and the new factual basis had not been considered earlier. A fresh determination by the original authority was therefore required on the correct facts after hearing the appellant again, and the ruling was set aside and remanded.</description>
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      <description>Where an advance ruling rests on a factual premise later shown to be incorrect, it cannot be sustained if the appeal depends on materially different facts not examined by the original authority. The appellate authority noted that the dispute over research and development services turned on whether the relevant goods were supplied by a foreign customer or manufactured in India, and the new factual basis had not been considered earlier. A fresh determination by the original authority was therefore required on the correct facts after hearing the appellant again, and the ruling was set aside and remanded.</description>
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