Indo-Swiss DTAA | Period Of Reference Can't Be Excluded From Limitation U/S

Indo-Swiss DTAA: Period of Reference Can't Be Excluded from Limitation U/S 153B Income Tax Act If Reference Is Invalid: Delhi High Court The Delhi High Court has ruled that the period of reference under the Indo-Swiss Double Taxation Avoidance Agreement (DTAA) cannot be excluded from the limitation period under Section 153B of the Income Tax Act if the reference itself is invalid. This decision highlights the importance of the legal validity of international references for tax assessments. If a reference under a DTAA is found to be flawed, it cannot be used to extend the statutory time limits for assessment under domestic law.