Ruling of Advance Authority —– The petitioner challenged the impugned order dated 25th September, 2019 passed by the Appellate Authority for Advance Ruling, relying on a circular dated 3rd August, 2022 which was issued much after the passing of the order of the Advance Ruling authority as well as the order of the Appellate Advance Ruling Authority, by contending that the said circular is a clarificatory in nature and applies to the case of the petitioner. The court observed that the aforesaid circular is not applicable to the case of the petitioner since it does not directly cover the issue and subject raised, secondly order of the Advance Ruling Appellate Authority can not be faulted since the circular in question if at all presumed to be applicable in case of the petitioner, was not at all in existence at the relevant time or at the time of passing the impugned order.

Held that:- The Hon’ble High Court dismissed the writ petition.