AAR held that the specific question in respect of the nature of services rendered under the agreement or about the taxability of receipts for the services did not form part of any of the questionnaire or notices. Therefore, such notices issued prior to the filing of the application could not be a bar in terms of clause (i) of the proviso to section 245R(2) of the Act, to admission of the application. (AY. 2016-17)
Centrient Pharmaceuticals Netherlands, B. V., IN RE (2021) 436 ITR 54 / 319 CTR 672 (AAR)
S. 245R : Advance rulings-Procedure-Application-Notice-Questions raised in application are not pending before Income-Tax Authority-Issue of notice is not bar to application for this year-Application was admitted. [S. 142 (1) 143 (2)