The Indian branch of F Inc., Country J, conducted transactions worth 600 crores with SR Enterprises Pvt. Ltd., Hyderabad, during FY 2024-25. SR…
CA Final · Direct Tax Laws and International Taxation · MTP · January 2026
The Indian branch of F Inc., Country J, conducted transactions worth 600 crores with SR Enterprises Pvt. Ltd., Hyderabad, during FY 2024-25. SR Enterprises applied for an advance ruling in January 2025 to determine the tax implications for both itself and the non-resident F Inc. The Board for Advance Rulings (BAR) accepted the application and pronounced its ruling on 30.04.2025 and said ruling was communicated to SR Enterprises Pvt. Ltd. on the same date. SR Enterprises Pvt. Ltd. was, however, not satisfied with said ruling. State whether the advance ruling pronounced by BAR is binding on SR Enterprises Pvt. Ltd. Is there any remedy available to SR Enterprises Pvt. Ltd. if it is aggrieved with the said ruling? Examine.
Suggested Answer and Working Notes:
Advance ruling pronounced by Board for Advance Rulings is not binding on SR Enterprises Pvt. Ltd. Section 245W provides that the applicant who is aggrieved by any ruling pronounced or order passed by the Board for Advance Rulings may appeal to the High Court against such ruling. He has to do so within sixty days from the date of the communication of that ruling or order, in the prescribed form and manner. Accordingly, if SR Enterprises Pvt. Ltd. is aggrieved by the advance ruling pronounced by BAR, it can file an appeal before the High Court on or before 29th June 2025. The High Court can grant extension of a further period of 30 days for filing the appeal, if it is satisfied, on an application made by SR Enterprises Pvt. Ltd. in this behalf, that it was prevented by sufficient cause from presenting the appeal within the 60 days period as specified above.
Topics: Deductions from Gross Total Income
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