SC to Examine Limitation Extension Denied Due to Invalid DTAA Reference for Pre-2011 Period

PCIT Vs Praveen Sawhney (Supreme Court of India) The case concerns whether the Income Tax Department could extend the limitation period for completing assessment under Section 153B of the Income Tax Act, 1961 based on a request for information made to Swiss authorities under the Indo-Swiss Double Taxation Avoidance Agreement (DTAA). Search and seizure operations were conducted in July 2011, followed by assessment proceedings for multiple assessment years. The Assessing Officer passed the assessment order on 04.03.2015. The Revenue contended that the limitation period stood extended by one year...