Binding Nature of Advance Ruling and Scope of Judicial Review

The Division Bench clarified that while advance rulings are binding on the applicant, they remain amenable to constitutional challenge under Articles 226/227. However, judicial review is confined to process, legality, and perversity, not merits substitution. 

On facts, the Court intervened to correct classification inconsistency, holding that identical tobacco products cannot be subjected to differential tax treatment, thereby restoring parity and setting aside contrary advance rulings.