What if the members of the AAAR also happen to differ on any point or points referred to in appeal or reference?

In such cases, it shall be deemed that no advance ruling can be issued in respect of the question under the appeal or reference.
This provision leads to a dead-end and renders the mechanism of advance ruling useless in questions where the members of AAAR are divided. However, the applicant may escalate the issue by preferring a writ before the jurisdictional High Court, if he does not wish to continue with uncertainty.