Generally, an advance ruling, whether favourable or otherwise, is final and will not be subject to the appeal process provided in the Income Tax Act.
If you disagree with our ruling, you need not follow it though you must declare in your Income Tax Return for the relevant Year of Assessment that you have obtained but have not relied on our advance ruling. We will review this difference in opinion when we review your Income Tax Return.
You may appeal against any assessment raised on the basis of our advance ruling under the normal objection provisions in section 76(2) of the Income Tax Act.