https://www.taxtmi.com/caselaws?id=242387 The application was rejected as the issue was pending before the Income-tax Authorities, with returns filed and notices issued before the application. The Revenue's objection based on the proviso to section 245R(2) of the Act was upheld, emphasizing that debatable issues cannot be adjudicated without a notice under section 143(2). The Authority clarified that the mere filing of a return does not automatically lead to the examination of all questions raised in the return, maintaining that jurisdiction arises only upon the issuance of a notice under section 143(2). en-us Fri, 10 Jan 2014 00:00:00 +0530 Mon, 07 Apr 2014 17:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=242387 The application was rejected as the issue was pending before the Income-tax Authorities, with returns filed and notices issued before the application. The Revenue's objection based on the proviso to section 245R(2) of the Act was upheld, emphasizing that debatable issues cannot be adjudicated without a notice under section 143(2). The Authority clarified that the mere filing of a return does not automatically lead to the examination of all questions raised in the return, maintaining that jurisdiction arises only upon the issuance of a notice under section 143(2). Case-Laws Income Tax Fri, 10 Jan 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=242387