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Bar of Application for Advance Ruling Where Matter Pending Consideration before income tax Authorities

Section 245R (2) provides for the rejection of application for advance rulings. The said section provides that the Authority may, after examining the application and the records called for, by order, either allow or reject the application. The proviso to this section provides that the authority shall not allow the application where the question raised in the application,


The theory of ‘last seen together’ is one where two persons are ‘seen together’ alive and after an interval of time, one of them is found alive and the other dead. If the period between the two is short, presumption as to the person alive being the author of death of the other can be drawn. Time gap should be such as to rule out possibility of somebody else committing the crime.

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