https://www.taxtmi.com/caselaws?id=404634 An advance ruling application may be refused at admission under section 245R(2) only where the Revenue shows material facts indicating a prima facie design to avoid tax by illegal or improper means. On the facts, no such material was placed on record, so the anti-avoidance objection failed. The objections on residential status were ascertainable from the stated period of stay abroad, and the other objections went to the merits of the questions on TDS under section 192 for seconded employees and the related foreign tax credit issue, rather than to admissibility. The application was therefore admitted for hearing on the merits. en-us Thu, 17 Dec 2020 00:00:00 +0530 Wed, 15 Sep 2021 17:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=404634 An advance ruling application may be refused at admission under section 245R(2) only where the Revenue shows material facts indicating a prima facie design to avoid tax by illegal or improper means. On the facts, no such material was placed on record, so the anti-avoidance objection failed. The objections on residential status were ascertainable from the stated period of stay abroad, and the other objections went to the merits of the questions on TDS under section 192 for seconded employees and the related foreign tax credit issue, rather than to admissibility. The application was therefore admitted for hearing on the merits. Case-Laws Income Tax Thu, 17 Dec 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=404634