Societe Generale vs Commissioner Of Income-Tax

The Supreme Court addressed the jurisdiction of the Authority for Advance Rulings under Section 245R of the Income-tax Act, 1961, concluding that the Authority should not have entertained the application while assessment proceedings were pending. The Court allowed the appellant to withdraw the application before the Authority, thereby setting aside the impugned judgment and order. The appellant is permitted to raise the issue of the applicable tax rate for the assessment year 1996-97 before the relevant authorities independently of the Authority's prior decision.