(iii) Universe India Ltd., an Indian public-sector undertaking, undertook a transaction with Moon Pte. of Singapore. The expected tax liability in…

(iii) Universe India Ltd., an Indian public sector company would fall under the definition of applicant for advance ruling since the value of the transaction with Moon Pte. of Singapore, being a non-resident is 100crores or more, as its tax liability itself is 56crores. Note – The public sector company is notified for the purpose of section 245N(b)(A) (IV) . Since in this sub-sub-clause (IV) there is no linking or reference with any of the sub-clause of clause (a), it is possible that a public sector company is an applicant for advance ruling without any monetary limit. In such case, Universe India Ltd., being a public sector undertaking, can apply for advance ruling for its own tax liability.