AAR application to be rejected if not complies Section 245R

Once the conclusion is reached that the application for advance ruling filed under section 245Q is hit by one or all of the embargoes laid down in the proviso to section 245R(2), the Authority  has no option but to reject the application in limine; it is not open to the Authority to ignore the legal bar created by the proviso notwithstanding the discretion conferred on the Authority in apparently wide terms under the main provision i.e., sub-section (2).

ADVANCE RULING DETAILS
THE AUTHORITY FOR ADVANCE RULINGS (INCOME-TAX) NEW DELHI
Microsoft Operations Pvt. Ltd., In re
Advance Ruling No.: AAR No. 781 of 2008

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