https://www.taxtmi.com/caselaws?id=408583 An advance ruling application was held non-maintainable where the questions raised were already pending before the income-tax authorities on substantially identical facts. The ruling found that receipts under the system fund support services agreement and the reservation system facility agreement involved services materially identical to those examined in earlier assessments, and that the change in contractual form and payment routing through a different group entity did not alter the core tax issue. As the present questions overlapped with issues already under examination and appeal, the bar in the proviso to section 245R(2) was attracted and the application was rejected. en-us Wed, 17 Feb 2021 00:00:00 +0530 Fri, 02 Jul 2021 16:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=408583 An advance ruling application was held non-maintainable where the questions raised were already pending before the income-tax authorities on substantially identical facts. The ruling found that receipts under the system fund support services agreement and the reservation system facility agreement involved services materially identical to those examined in earlier assessments, and that the change in contractual form and payment routing through a different group entity did not alter the core tax issue. As the present questions overlapped with issues already under examination and appeal, the bar in the proviso to section 245R(2) was attracted and the application was rejected. Case-Laws Income Tax Wed, 17 Feb 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=408583