S. 201 : Deduction within supply – Incapacity to subtract or pay – Fee in order to Non-residents – Applying of recipient admitted and you will pending just before Power to possess Advance Rulings – Whenever you are adjudicating the challenge, the brand new Authority commonly adjudicate the jurisdictional issue of chargeability regarding tax [S. 201(1), 201(IA), 245R, Ways 226]
On the writ the brand new Judge kept you to if you’re carrying out new adjudication, the fresh Expert for Advance Rulings carry out first influence about if new remittances for the thing was indeed rechargeable to taxation and you may solution 
good speaking purchase, just after offering an individual hearing, when your buy enacted try bad to the interests of your assessee, it could not considering impact getting 30 days, and if the newest power is of your own consider it was had a need to wait a little for the decision of your Expert having Get better Rulings in the matter towards person low-resident, it may take this time under consideration also.(AY.2012-13, 2013-14)
S. 201 : Deduction at origin – Inability to deduct or shell out – Simple records in levels – No accrual of cash – Not liable to subtract taxation at origin [S. 40(a)(i), 40(a) (ia), 192, 194C, 201(IA)