Clause (ix) of Section 153B Inapplicable for Invalid DTAA Reference: Delhi HC

PCIT Vs Smt. Sneh Lata Sawhney (Delhi High Court) Conclusion: Clause (ix) of the Explanation to Section 153B could not be invoked to exclude the period of reference under the Indo-Swiss DTAA, if the reference itself was invalid. Thus, no request could be made by Department for information relating to period prior to 01.04.2011 in terms of the Indo-Swiss DTAA. Read SC Interim Order in this case: SC to Examine Limitation Extension Denied Due to Invalid DTAA Reference for Pre-2011 Period Held: Department had information regarding assessee maintaining a Swiss bank account and was confronted with ...