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Issues: Whether the application for advance ruling was barred by the proviso to section 245R(2) of the Income-tax Act, 1961 on the ground that the matter was already pending before the income-tax authorities.
Analysis: Mere filing of a return does not by itself attract the statutory bar. The relevant question is whether the specific issue raised in the application was already pending for adjudication before the income-tax authorities. In the present case, although returns had been filed before the application, the notice under section 143(2) was issued only after the application had been made. On that footing, the matter could not be treated as pending before the income-tax authorities when the application was filed.
Conclusion: The application was not hit by the bar under section 245R(2) and was admitted.
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