Ruling on general questions

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....ication of this Act to a class of persons or class of transactions.       (2)  A ruling issued by the Commissioner under this section may be issued subject to such restrictions and conditions as the Commissioner may deem fit.       (3)  The ruling shall be treated as coming into effect on the date stated in the ruling (which may be ....

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....uling, the ruling purports to apply to the transaction or action undertaken by the person; no assessment which is inconsistent with the ruling, may be raised by the Commissioner against that person and no penalty may be imposed on the person if the ruling is later held incorrect.      Explanation: A person may rely on the Commissioner's ruling or on the determination made....