(1) In cases where any one or more than one person makes a request in writing to become clear as to the  distribution, allocation or allotment to be made by the Department on the basis of arms length in respect of the amounts to be included or deducted in computing the income of any person pursuant to Subsection (1) of Section 33 of the Act, the Department may issue a notice in writing as follows:
(a) In a manner that the period of the notice in writing does not exceeds Five income years at a time,
(b) In a manner that the notice in writing can be renewed notwithstanding anything contained in
Clause (a).
(2) The notice in writing referred to in sub-rule (1) shall be binding to the Department and the party making such request. Provided that, in cases where the Department agrees to the request made by the concerned applicant, the notice in writing shall be invalid.