The AAR held that the questions raised in notices and questionnaires not connected with questions raised in application. Issue of dividend distribution tax did not appear in any of the questions. The claim for the refund of excess dividend distribution tax was made by letter after the filing of the application which would not create any pendency on the date of application filed earlier. Thus, the questions raised in the present application were not pending before the Income-tax authority on the date of filing of the application and the bar in terms of clause (i) of the proviso to section 245R(2) was not attracted. The application was to be admitted under section 245R(2) of the Act. (AAR No. 25 of 2018 dt. 2-2-2021).  (AY. 2016-17)