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2014 (1) TMI 608 - AAR - Income TaxAdmissibility of the application - Held that:- Only when the issues are referred 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, return of income was filed before filing application to the Authority for Advance Rulings - Notice under section 143(2) was issued after the application was filed before the Authority - Following Hyosung Corporation Korea [2013 (8) TMI 487 - AUTHORITY FOR ADVANCE RULINGS] - The question cannot be said to be already pending before the Income-tax Authorities, as no notice under Section 143(2) was issued before filing the application though return was filed - The application is, admitted under section 245R(2) of the IT Act, 1961 – Decided in favour of assessee.
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