AAR – WaveField Inseis ASA – Date of filing of the return is relevant to consider applicability of proviso to section 245R(2)

In Re Wave Field Inseis ASA (AAR)- When this Authority took the view in Monte Harris and other cases that the date of the filing of the application before the Authority should be the crucial date  for determining the question of the applicability of clause (i) of the proviso to section 245R(2) of the Act and not the date when the application comes up for hearing either under section 245R(2) or under section 245R(4) of the Act, the Authority was searching for a definite and consistant terminus a quo. This Authority felt that the period could not be left to the vagaries of the progress of the a...