Ruling of AAR is binding upon Revenue authorities

EY Global Services Ltd. Vs ACIT (ITAT Delhi)

ITAT finds itself in agreement with the submissions made by the ld. DR for the Revenue. AO has only followed the ruling of AAR in assessee’s own case and as per the provisions of section 245S of the Act, ruling of Hon’ble AAR is binding upon the Revenue authorities. The provisions of section 295S reads as under :-

“245S. (1) The advance ruling pronounced by the Authority under section 245R shall be binding only-

(a) on the applicant who had sought it;

(b) in respect of the transaction in relation to which the ruling had been sought, and

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