Reassessment disclosure requirements permit stated reasons without revealing information sources, but prior-taxation claims require full examination b...
Independent assessment discretion and corroborated electronic evidence determine validity of on-money additions and undisclosed-consideration assessme...
Service of notice and contractual debt acknowledgment preserved insolvency admission against a corporate guarantor despite limitation and natural just...
ITAT held that assessments under Section 153A were time-barred due to improper information exchange request. The tribunal relied on jurisdictional HC ruling which determined that references not complying with Indo-Swiss DTAA protocol's Article 14 cannot extend assessment limitation period. Specifically, requests made after 30/08/2010 violating the amending protocol's provisions were deemed invalid. Consequently, all challenged assessment orders and consequential penalty orders were set aside, affirming strict adherence to statutory limitation timelines and procedural requirements for international information exchange mechanisms.
ITAT held that assessments under Section 153A were time-barred due to improper information exchange request. The tribunal relied on jurisdictional HC ruling which determined that references not complying with Indo-Swiss DTAA protocol's Article 14 cannot extend assessment limitation period. Specifically, requests made after 30/08/2010 violating the amending protocol's provisions were deemed invalid. Consequently, all challenged assessment orders and consequential penalty orders were set aside, affirming strict adherence to statutory limitation timelines and procedural requirements for international information exchange mechanisms.
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