101B. Appeal to National Appellate Authority.—
(1) Where, in respect of the questions referred to
in sub-section
(2) of section 97, conflicting Advance Rulings are given by the Appellate Authorities of
two or more States or Union territories or both under sub-section
(1) or sub-section
(3) of section 101, any
officer authorised by the Commissioner or an applicant, being distinct person referred to in section 25
aggrieved by such Advance Ruling, may prefer an appeal to National Appellate Authority:
Provided that the officer shall be from the States in which such Advance Rulings have been given.
(2) Every appeal under this section shall be filed within a period of thirty days from the date on which
the ruling sought to be appealed against is communicated to the applicants, concerned officers and
jurisdictional officers:
Provided that the officer authorised by the Commissioner may file appeal within a period of ninety
days from the date on which the ruling sought to be appealed against is communicated to the concerned
officer or the jurisdictional officer:
Provided further that the National Appellate Authority may, if it is satisfied that the appellant was
prevented by a sufficient cause from presenting the appeal within the said period of thirty days, or as the
case may be, ninety days, allow such appeal to be presented within a further period not exceeding thirty
days.
Explanation.—For removal of doubts, it is clarified that the period of thirty days or as the case may
be, ninety days shall be counted from the date of communication of the last of the conflicting rulings
sought to be appealed against.
(3) Every appeal under this section shall be in such form, accompanied by such fee and verified in
such manner as may be prescribed.