Assessee filed an application for advance ruling under section 245Q of the Act on 30-11-2018 on the issue of whether dividend distribution tax (DDT) paid to its shareholder is a tax on dividend and whether benefit of lower rate of 10% under the treaty applies. The AAR observed that notices were issued to the assessee under section 143(2) and 142(1) of the Act on 3-7-2017 and 9-7-2018 respectively. However, the issue of DDT was not present in these notices and the claim for refund was made after filing the present application. Thus, the questions raised in the present application were not found pending before any income-tax authority on the date of filing of the application under section 245R(2) and the application was admitted under section 245R(2). (AAR No. 25 of 2018 dt. 2-2-2021)  (AY. 2016-17)