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2014 (1) TMI 607 - AAR - Income TaxAdmissibility of application u/s 245R - Held that:- Only when the issues are shown in the return and notice under section 143(2) is issued, the question raised in the application will be considered as pending for adjudication before the Income-tax Authorities - In the case of assessee company - Not only return of income was filed but even notices under section 143(2) and 142(1) were already issued before filing of the application - Return of income for the relevant assessment year was filed on 30.9.2008 and a revised return was filed on 31.3.2010 i.e. before filing the application to the Authority for Advance Rulings on 19.5.2011 - Notice under section 143(2) was issued on 20.9.2010 which was before filing the application - The assessment was also completed under section 143(3) of the Act by the Assessing Officer on 1.2.2012 – It is clear that the question was already pending before the Income-tax Authorities and the application is barred by Proviso (1) of section 245R(2) of the Act – Decided against assessee.
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