AAR held that the questions raised in the application were in respect of the amounts received by the assessee from ABC India for the services rendered under agreements effective from April 1, 2019 and the first year in which these services would be subject to examination by the Department would be assessment year 2020-21. The proceedings pending before the Department were for earlier assessment years. The additions made by the Assessing Officer were confirmed by the Commissioner (Appeals) and the issues were pending before the Tribunal. The questions raised in the application were in respect of the issues which were already pending before the Income-tax authority in different years. Therefore, the bar under clause (i) of the proviso to section 245R(2) was squarely attracted and the application was not to be admitted. (AAR No. 10 of 2020 dt.17-2-2021)  (AY. 2012-13 to 2016-17)