Rule 201 — Certification of copies of advance rulings pronounced by Board for Advance Rulings under section 384(8). Made under s.384 of the Income-tax Act, 2025.
Rule 201 gives effect to Section 384 of the Income-tax Act, 2025. A rule cannot go beyond the section it serves: where the two seem to differ, the section governs.
The rule fixes who certifies copies of an advance ruling for section 384(8). The copy of the advance ruling pronounced by the Board, to be sent to the applicant and to the Commissioner having jurisdiction over his case, is to be certified to be a true copy of the ruling by the Commissioner or Deputy Commissioner or Board for Advance Rulings, as the case may be.
Section 384(8) requires copies of a ruling to be sent to the applicant and to the jurisdictional Commissioner, but does not say what makes a copy authentic. The rule names the officers whose certification does that, so a copy relied on later can be shown to be a true copy of what was pronounced.
The rule goes to authentication, not to the ruling itself; the certification adds nothing to what the ruling decides. The certifying authority is one of three named, taken as the case may be, so a copy carrying no such certification is not the certified copy the rule contemplates.
You meet it as the certified copy of the ruling that reaches you after the Board for Advance Rulings pronounces it, and as the copy the jurisdictional Commissioner holds.
shall be certified to be true copy thereof by the Commissioner or Deputy Commissioner or Board for Advance Rulings, as the case may be