Where application for advance ruling was filed prior to issue of notice under section 143(2) and thus, questions raised by applicant were not already pending before Income-tax Authorities, clause (i) of proviso to section 245R(2) was not found attracted. Applicant  had  sought advance ruling on application of beneficial provisions of DTAA for determination of Dividend Distribution Tax (DDT) rate on dividend to non-resident shareholder, there was no design to avoid tax by any illegal or improper means, hence, clause (iii) of proviso to section 245R(2) was not attracted. Application was admitted.