Advance Ruling u/s 245R Finds No Evidence of Tax Avoidance; Merits to Be Addressed in Hearing.

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....Advance ruling application u/s 245R - We do not find any design to avoid tax by any illegal or improper means. The submission of the Revenue is mostly on the merits of the case which has to be considered in the course of merit hearing. Merely because the applicant has taken over the responsibility of risk of loss or damage till the equipments were delivered in Delhi and also that of insurance etc; it does not establish that the transaction was designed prima-facie for avoidance of tax. - AAR....