Private Rulings Cannot Override the correct statutory interpretation of the law by a court of competent jurisdiction.

"...This action raises significant questions regarding the principle of legitimate expectation, a cornerstone of administrative justice. A taxpayer is entitled to rely on clear, unambiguous and unqualified representations made by a tax authority. For the Respondent to unilaterally resile from its own binding ruling without compelling justification risks undermining legal certainty and fairness in tax administration. While the Appellant’s conduct is a matter of concern, a private ruling cannot, however, override the correct statutory interpretation of the law by a court of competent jurisdiction. The ultimate duty of this Court is to interpret and apply the law as enacted by Parliament."