AAR held  that the return of the assessee for assessment year 2018-19 was initially selected for scrutiny on ten specific issues, one of the issues being “deduction claimed for industrial undertaking under section 80-IA / 80-IAB / 80-IAC / 80-IB / 80-IC / 80-IBA / 80-ID / 80-IE / 10A / 10AA ”. The notice under section 143(2) for assessment year 2018-19 was issued prior to the filing of the present application. In the application, the questions raised were in respect of the assessee’s eligibility for deduction under section 80-IA of the Act. Thus, the question raised in the application was already pending before the Income-tax authority. The issue of pendency could be brought to the notice of the Authority even in the course of hearing. The fact regarding prior issue of notice under section 143(2) for the assessment year 2018-19 was not mentioned by the assessee in its application filed before the Authority. As the notice was received prior to the filing of the application the assessee should have disclosed this fact in the application. That as for the assessment year 2019-20, in the questions raised before the Authority no assessment year was mentioned. The eligibility for deduction under section 80-IA had to be decided in the first year of claim. Once the claim was found eligible in the first year of claim the assessee was entitled to deduction in all the subsequent years. Further, it was not necessary that the issues raised in the application should be pending in all the years involved. Even if the issue was pending in a single year, it made the application ineligible for admission under clause (i) of the proviso to section 245R(2) of the Act. The bar in terms of clause (i) of the proviso to section 245R(2)  was attracted and the application could not be admitted.( AY. 2018-19, 2019-20)