86. Ruling on general questions.

(a) the Commissioner has published a ruling in respect of a class of persons or transactions;
(b) a person implements a transaction or undertakes any action in reliance on the ruling;
(c) the ruling has, at the time of implementing the transaction or undertaking the action, not been withdrawn by the Commissioner; and
(d) according to the terms of the ruling, the ruling purports to applies to the transaction or action undertaken by the person; no assessment may be raised by the Commissioner against that person which is inconsistent with the ruling and no penalty may be imposed on the person if the ruling is later held incorrect.
Chapter XIII
Administrative Penalties and Offences