https://www.taxtmi.com/caselaws?id=210755 The AAR rejected the application before it, citing jurisdictional constraints under clause (i) of the proviso to section 245R(2) of the Income-tax Act. The interpretation emphasized that the Authority lacks jurisdiction when the question raised is pending before any Income-tax Authority, regardless of whether it was explicitly raised. The decision highlights the need for strict construction of jurisdictional bars to ensure clarity and certainty in resolving disputes, ultimately leading to the dismissal of the application. en-us Thu, 02 Feb 2012 00:00:00 +0530 Tue, 11 Dec 2012 14:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=210755 The AAR rejected the application before it, citing jurisdictional constraints under clause (i) of the proviso to section 245R(2) of the Income-tax Act. The interpretation emphasized that the Authority lacks jurisdiction when the question raised is pending before any Income-tax Authority, regardless of whether it was explicitly raised. The decision highlights the need for strict construction of jurisdictional bars to ensure clarity and certainty in resolving disputes, ultimately leading to the dismissal of the application. Case-Laws Income Tax Thu, 02 Feb 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=210755