https://www.taxtmi.com/caselaws?id=445444 A reference for exchange of information under the India-Switzerland tax treaty did not extend the limitation period for reassessment where the requested information related to assessment year 2008-09. The treaty protocol and implementing notification limited the exchange-of-information mechanism to fiscal years beginning on or after 1 April 2011, so the amended arrangement could not apply retrospectively to the earlier year. As the reference was incapable of yielding information for the relevant period, it could not trigger the statutory extension of time under section 153B. The reassessment completed on 29.12.2016 was therefore time-barred. en-us Tue, 31 Oct 2023 00:00:00 +0530 Wed, 08 Nov 2023 17:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445444 A reference for exchange of information under the India-Switzerland tax treaty did not extend the limitation period for reassessment where the requested information related to assessment year 2008-09. The treaty protocol and implementing notification limited the exchange-of-information mechanism to fiscal years beginning on or after 1 April 2011, so the amended arrangement could not apply retrospectively to the earlier year. As the reference was incapable of yielding information for the relevant period, it could not trigger the statutory extension of time under section 153B. The reassessment completed on 29.12.2016 was therefore time-barred. Case-Laws Income Tax Tue, 31 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445444