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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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