https://www.taxtmi.com/caselaws?id=440866 Under the India-Switzerland DTAA, a request for information can extend the limitation period for assessment only within the years covered by the treaty amendment and notification. A reference seeking information for periods before 1 April 2011 was treated as invalid for those earlier years, so it could not support extension of time under Explanation IX to section 153B. On that basis, the reassessment under section 153A read with section 143(3) was time-barred and quashed. The connected penalty under section 271(1)(c) also failed because it was entirely dependent on the assessments and could not survive once the assessments were set aside. en-us Thu, 18 May 2023 00:00:00 +0530 Thu, 27 Jul 2023 11:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=440866 Under the India-Switzerland DTAA, a request for information can extend the limitation period for assessment only within the years covered by the treaty amendment and notification. A reference seeking information for periods before 1 April 2011 was treated as invalid for those earlier years, so it could not support extension of time under Explanation IX to section 153B. On that basis, the reassessment under section 153A read with section 143(3) was time-barred and quashed. The connected penalty under section 271(1)(c) also failed because it was entirely dependent on the assessments and could not survive once the assessments were set aside. Case-Laws Income Tax Thu, 18 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=440866