https://www.taxtmi.com/caselaws?id=785662 A foreign-tax-information reference can extend limitation under Section 153B only if the treaty mechanism authorises disclosure for the relevant fiscal year or taxable event. Reading the India-Hong Kong exchange-of-information protocol against the earlier India-Swiss protocol, the Delhi HC held that the Hong Kong protocol permitted disclosure only of information preceding its effective date and only where foreseeably relevant to a later fiscal year or taxable event. Because the reference to the FT&TR Division did not validly cover the assessment year in question, the Revenue could not invoke clause (ix) of the Explanation to Section 153B to extend limitation. The assessment orders were therefore time-barred and the assessee's position was sustained. en-us Thu, 22 Jan 2026 00:00:00 +0530 Thu, 29 Jan 2026 09:51:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785662 A foreign-tax-information reference can extend limitation under Section 153B only if the treaty mechanism authorises disclosure for the relevant fiscal year or taxable event. Reading the India-Hong Kong exchange-of-information protocol against the earlier India-Swiss protocol, the Delhi HC held that the Hong Kong protocol permitted disclosure only of information preceding its effective date and only where foreseeably relevant to a later fiscal year or taxable event. Because the reference to the FT&TR Division did not validly cover the assessment year in question, the Revenue could not invoke clause (ix) of the Explanation to Section 153B to extend limitation. The assessment orders were therefore time-barred and the assessee's position was sustained. Case-Laws Income Tax Thu, 22 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785662