https://www.taxtmi.com/caselaws?id=210756 The Authority rejected the application challenging the jurisdiction of the Advance Ruling Authority under section 245R(2) of the Income-tax Act. It held that filing a return of income related to the transaction in question barred the application before the Authority. Emphasizing the need for a strict interpretation of the provision, the Authority highlighted that its jurisdiction is limited by the Act's provisions. The timing of filing the return vis-a-vis the advance ruling application determines the applicability of the proviso, with the relevant date being the filing of the return of income. The rejection was further justified by the applicant's lack of reasonable diligence in approaching the Authority. en-us Fri, 03 Feb 2012 00:00:00 +0530 Fri, 25 Jan 2013 16:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=210756 The Authority rejected the application challenging the jurisdiction of the Advance Ruling Authority under section 245R(2) of the Income-tax Act. It held that filing a return of income related to the transaction in question barred the application before the Authority. Emphasizing the need for a strict interpretation of the provision, the Authority highlighted that its jurisdiction is limited by the Act's provisions. The timing of filing the return vis-a-vis the advance ruling application determines the applicability of the proviso, with the relevant date being the filing of the return of income. The rejection was further justified by the applicant's lack of reasonable diligence in approaching the Authority. Case-Laws Income Tax Fri, 03 Feb 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=210756