https://www.taxtmi.com/caselaws?id=772781 The exclusion of time under Explanation (ix) to section 153B applies only when an exchange-of-information request is made under a treaty covered by section 90 or section 90A and within that treaty's operative temporal scope. A request made after the Indo-Swiss DTAA protocol substitution, but for a period outside the new article's effective reach, was not maintainable under the treaty. On that basis, the limitation period for reassessment could not be extended, the assessments were barred by limitation, and penalty orders founded on those assessments could not survive. en-us Thu, 29 May 2025 00:00:00 +0530 Fri, 13 Jun 2025 08:41:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=772781 The exclusion of time under Explanation (ix) to section 153B applies only when an exchange-of-information request is made under a treaty covered by section 90 or section 90A and within that treaty's operative temporal scope. A request made after the Indo-Swiss DTAA protocol substitution, but for a period outside the new article's effective reach, was not maintainable under the treaty. On that basis, the limitation period for reassessment could not be extended, the assessments were barred by limitation, and penalty orders founded on those assessments could not survive. Case-Laws Income Tax Thu, 29 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=772781