Order passed by the Tax Officer after applying the AAR ruling in petitioner’s own case cannot be revised by the Commissioner based on some other AAR

Writ petition No. 866 of 2010 filed with the Bombay High Court Prudential Assurance Company Limited (‘the Petitioner’ or ‘the Company’), a sub-account duly registered with the Securities and Exchange Board of India (‘SEBI’) filed a writ petition (Writ petition No. 866 of 2010 ) with the Bombay High Court against the show -cause notice issued under section 263 of the Income Tax Act, 1961  issued by the Commissioner of Income-tax (Commissioner). The Commissioner was seeking to revise an assessment order determined on the basis of a ruling of the Authority for Advance Ruling (‘the...