AAR in case of assessee, a UAE resident, ruled that she was eligible for DTAA benefits. AO reopened assessment of assessee on ground that subsequent AAR ruling in another case held that benefits of DTAA would not be available as assessee was not chargeable to tax in UAE. On writ the Court held that  since subsequent ruling cannot as a matter of plain intendment and meaning of section 245-S displace binding character of ruling rendered between applicant-assessee and revenue, AO had exceeded his jurisdiction to reopen said assessment.  (AY. 1997-98 to 2000-01)