No Bar U/s. 245R(2)(i) merely due to notice asking applicant to produce any evidence in support of its return

CIT Vs Authority for Advance Ruling (Delhi High Court) The issue under consideration is whether the question raised in the notice under Section 143(2) can be stated to be ‘pending’ to attract clause (i) of the proviso to Section 245R(2) of the Act? In the present case, the petitioner i.e CIT argues that since the questions raised in the Application before the AAR were already pending before the Assessing Officer, the AAR was barred from assuming jurisdiction in view of the threshold bar enshrined in clause (i) under Proviso to section 245 R (2) of the Act. High Court states that th...