https://www.taxtmi.com/caselaws?id=205822 The proviso to section 245R(2) bars an advance ruling application where the same question is already pending before an income-tax authority, appellate tribunal or court, even if the pending proceedings concern another person after deletion of the words "in the applicant's case". On the stated facts, the payer's appeal involved the taxability in India of the payment to the applicant, the applicability of section 195, and related disallowance under section 40(a)(i), so the advance ruling authority had no jurisdiction and the application was not maintainable. en-us Wed, 03 Aug 2011 00:00:00 +0530 Mon, 26 Mar 2012 14:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=205822 The proviso to section 245R(2) bars an advance ruling application where the same question is already pending before an income-tax authority, appellate tribunal or court, even if the pending proceedings concern another person after deletion of the words "in the applicant's case". On the stated facts, the payer's appeal involved the taxability in India of the payment to the applicant, the applicability of section 195, and related disallowance under section 40(a)(i), so the advance ruling authority had no jurisdiction and the application was not maintainable. Case-Laws Income Tax Wed, 03 Aug 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=205822