Tax Assessment u/s 153A Barred by Limitation; Invalid Reference to Swiss Info Blocks Extension Argument.

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....Assessment framed u/s 153A r.w.s 143(3) as barred by limitation - We are of the considered view that the information called for by the department from Swiss authorities could not have been received by them for the period prior to 01.04.2011. Therefore, it would be a futile exercise to wait for such information, and that too, by an invalid reference. Therefore, in our considered opinion, the period of limitation could not be extended as claimed by the Revenue - AT....