Black Money Act limitation turns on notice service; pre-notice foreign information exchange time cannot be excluded from assessment period.

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....Assessment under the Black Money Act starts only on service of notice under section 10, so no assessment proceedings exist in law before that date. On that basis, time excluded for foreign information exchange under Explanation 1 to section 11 can cover only the period overlapping with the running assessment period, not any earlier period before notice service. The Tribunal held that the Revenue wrongly excluded pre-notice time, and the assessment was completed after the last permissible date. The order was therefore time-barred, without jurisdiction and non est, and was quashed; the merits were left open and the departmental appeal became infructuous.....