India-Hong Kong DTAA Info Clause Not Retrospective; ITAT Quashes Time-Barred Assessments

Sanjay Jain Vs DCIT (ITAT Delhi)

Exchange of information clause under India–Hong Kong DTAA not retrospective – Assessments beyond limitation quashed by Delhi ITAT

Assessee challenged the validity of assessments completed u/s153A r.w.s. 144 on the ground that they were barred by limitation. AO had claimed an extended limitation based on a reference made to Hong Kong under a tax treaty (DTAA).

A search was conducted on Assessee on 28.02.2017. Assessments for AYs 2011–12 to 2017–18 were completed on 24.12.2019. The normal time limit u/s153B expir

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