Limitation under the Black Money Act barred assessment where relaxation notifications did not extend the statutory time limit.

Section 11 of the Black Money Act prescribes a two-year limit for completing assessment from the end of the financial year in which notice under section 10(1) is issued, subject to the statutory exclusion for exchange-of-information references. The relaxation notifications under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 were held not to extend limitation for assessments under the Black Money Act, as they applied to specified enactments and not to this Act. On the stated facts, the assessment order was passed after the permissible period and was therefore time-barred; the proceedings were quashed in favour of the assessee.

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Issues: Whether the assessment order under section 10(3) of the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 was barred by limitation, and whether the extensions notified under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 applied to proceedings under the Black Money Act.

Analysis: The Tribunal noted that section 11 of the Black Money Act prescribes a two-year limitation from the end of the financial year in which notice under section 10(1) is issued, subject to the statutory exclusion for the period relating to exchange-of-information references. The Tribunal further held that the relaxation notifications issued under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 extended time limits for specified enactments such as the Income-tax Act and the Prohibition of Benami Property Transaction Act, 1988, but did not extend the limitation for completion of assessment under the Black Money Act. On the facts, the notice was issued on 10.04.2018 and the assessment ought to have been completed by 31.03.2021; the order dated 17.02.2022 was therefore beyond limitation.

Conclusion: The assessment proceedings were time-barred and were quashed; the legal ground was accepted in favour of the assessee.

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