Search and seizure: abatement of earlier search bars use of prior seized material in later search-based assessments; relief limited to new documents f...
Admission of additional evidence under remand rules must await a meaningful remand report; failure to do so breaches natural justice and mandates rema...
Export Obligation Discharge Certificates for EPCG compliance cannot be questioned by Customs unless DGFT adjudicates and cancels them, so demands quas...
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Exchange of information under bilateral tax treaties was interpreted to require applicability to information relating to fiscal years beginning after the protocol's specified date, so the IndiaSwiss Article 26 applies only to fiscal years commencing after 01.04.2011 and the IndiaHong Kong Protocol clause 5(c) permits information only for fiscal years or taxable events after 30.11.2018 (effectively FY 2019-20/AY 2020-21). Consequently, a revenue authority could not compel information for the Assessment Year 2017-18, the reference to the Foreign Tax and Tax Research Division was held improper, and the assessing officer cannot claim the one-year extension of limitation under the explanation to the Income Tax Act.
Exchange of information under bilateral tax treaties was interpreted to require applicability to information relating to fiscal years beginning after the protocol's specified date, so the IndiaSwiss Article 26 applies only to fiscal years commencing after 01.04.2011 and the IndiaHong Kong Protocol clause 5(c) permits information only for fiscal years or taxable events after 30.11.2018 (effectively FY 2019-20/AY 2020-21). Consequently, a revenue authority could not compel information for the Assessment Year 2017-18, the reference to the Foreign Tax and Tax Research Division was held improper, and the assessing officer cannot claim the one-year extension of limitation under the explanation to the Income Tax Act.
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