195.            Mr D has made an application to authority for obtaining advance ruling. Members of Authority differ on the question due to which advance ruling cannot be pronounced. Advise.

As per section 98(5), where the members of the Authority differ on any question on which the advance ruling is sought, they shall state the point or points on which they differ and make a reference to the Appellate Authority for hearing and decision on such question. Accordingly, question of Mr. D will be referred to Appellate for decision on the points of difference between members of Authority.