It said contrary to the expectation that a ruling would be given in six months (as per section 245R (6) of the I-T Act), the average time taken is stated to be around four years. This is primarily attributable to the large number of vacancies and delayed appointment of AAR members, the court said.
Amit Maheshwari, tax partner at AKM Global, a consultancy firm, said the advance ruling had lost its relevance considering the frequent delays and unfavourable orders which were coming of late. "Considering the various initiatives taken by the government to reduce litigation, this recommendation by the Supreme Court
has the potential to reduce litigation by binding tax authorities," he said.