The applicant raised the question before the AAR regarding the amounts received/receivable by applicant from ‘DLTPL’ are liable to tax in India. AAR held that questions raised in present application are in respect of contract with DLTPL dated 6-9-2018, which could not have been pending in Assessment years 2014-15 & 2015-16 as relevant assessment year for this contract is Assessment year 2019-20, objection of revenue regarding pending proceeding is not found correct, and, this, application is admitted under section 245R(2).