Application for advance ruling to be admitted if it was filed before issuance of notice u/s 143(2)

INCOME TAX : Where applicant had merely 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, further fact that application for advance ruling was filed prior to issue of notice under section 143(2)

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