Applicability of advance ruling :

(1) The advance ruling pronounced by the Authority or, as the case may be, the Appellate Authority under this chapter shall be binding only –

(a) on the applicant who had sought it in respect of any matter referred to in subsection

(2) of section 97 of the application for advance ruling;

(b) on the jurisdictional tax authorities in respect of the applicant.

(2) The advance ruling referred to in sub-section (1) shall be binding as aforesaid unless the law, facts or circumstances supporting the original advance ruling have changed.