(1) The Commissioner may, by notification, publish his ruling on the answer to

Ruliogon any question involvingthe interpretation of any issue under this Regulation or applicationof gmml this Regulation to a class of persons or class of transactions. queslions.

1. (2) A ruling issued by the Commissioner under this section may be issued subject to such restrictions and conditions as the Commissioner may deem fit. -, SERIES - I No. : 05 DATED 18"' AUGUST, 2005.
2. (3) The ruljng shall conkinto forceon the date mentioned in the ruling or, if no date is

stated in the ruling, on the date of publication in the

Official Gazette.

1. (4) where-
   • (a) the Commissioner has published a ruling in respect of a class of persons or transactions;
   • (b) a person implements a transaction or undertakes any action based on the ruling;
   • (c) the ruling has, at the time of implementing the transaction or undertaking the action, not been withdrawn by the Commissioner; and

(4 according to the terms of the ruling, the ruling purports to apply to the

traniaction or action undertaken by the person, no assessment which is inconsistent with the ruling, shall be made by the Commissioner or any other authority against that person and no penalty may be imposed on the person if the -- ruling is later held incorrect.

Explanation.- A person may rely on the ruling of the Commissioner or on the

determination made under section