Date of filing of the return is relevant date to consider the applicability of the proviso to section 245R(2) of the Act

Date of filing of the return is the relevant date to consider the applicability of the proviso to section 245R(2) of the Act, and that the filing of the return of income generates questions including the ones raised before this Authority, the jurisdiction to give a ruling in the present application has to be held to be barred. We are, therefore, constrained to reject the application as being barred by clause (i) of the proviso to section 245R(2) of the Act. AUTHORITY FOR ADVANCE RULINGS (INCOME TAX), NEW DELHI 3rd Day of February, 2012 A.A.R. No. 1050 of 2011 Applicant- Red Hat India Private L...