201.            Whether an advance ruling pronounced by the appellate authority can be challenged by the applicant or any income tax authority under article 226/227 of the constitution before the High Court or under article 136 of the constitution before the Supreme Court?

Article 226 & 227 empowers High Court to exercise jurisdiction over the courts and tribunals subordinate to it. Similarly, Article 136 of the constitution empowers the Supreme Court to exercise jurisdiction over the courts & tribunals subordinate to it.

The advance ruling appellate authority being a judicial body vested with powers of state under special law, is deemed “tribunal” within the meaning of expression under the article 136, 226, 227 of the constitution. Thus, the ruling pronounced by Appellate Authority of advance ruling can be challenged in High Court or Supreme Court. (section 99)