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Advance Ruling [Section 245N(a)] – Income Tax

Advance Ruling [Section 245N(a)] :

This term means

(1) a determination by the Authority in relation to a transaction which has been undertaken or is proposed to be undertaken by a non resident applicant and such determination shall include the determination of any question of law or of fact specified in the application ; or

(2) a determination by the Authority in relation to the tax liability of a non-resident arising out of a transaction which has been undertaken or is proposed to be undertaken by a resident applicant with such non-resident.

(3) a determination by the Authority in relation to the tax liability of a resident applicant arising out of a transaction which has been undertaken or is proposed to be undertaken by such applicant.

(4) a determination or decision by the Authority in respect of an issue relating to computation of total income which is pending before any Income-tax Authority or the Appellate Tribunal and such determination or decision shall include the determination or decision on any question of law or fact in relation to such computation of total income specified in the application.

(5) A determination or decision by the Authority whether an arrangement, which is proposed to be undertaken by any person being a resident or a non-resident, is an impermissible avoidance agreement.

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