Advance rulling q.5 of pm

Plz provide the answer of this ques.

Is it necessary the case should be pending in Assesse's case or any other case

A foreign company entered into contracts with several Indian companies for installation of

mobile telephone system and made an application to the Authority for Advance Rulings for

advance ruling on the rate of withholding tax on receipts from Indian companies. One of the

Indian companies had also made an application to the Assessing Officer for determination of

the rate at which tax is deductible on payment to the said foreign company. The Authority for

Advance Rulings rejected the application of the foreign company on the ground that the

question raised in the application is already pending before an income tax authority. Is the

rejection of the application of the foreign company justified in law?