Benefit of explanation (ix) of section 153B not available as reference to Indo-Swiss DTAA invalid

PCIT Vs Smt. Senh Lata Sawhney (Delhi High Court)

Delhi High Court held that the benefit of exclusion of time by virtue of Explanation (ix) of Section 153B of the Income Tax Act cannot be available here as reference made for information under Indo-Swiss DTAA was invalid. Accordingly, questions to law as framed are answered against the Revenue.

Facts- The question of law involved herein is whether the Income Tax Appellate Tribunal is correct in quashing the assessment order as barred by limitation without going into merits of the case and whether the ITAT is

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