Invalid Reference Limitation

In a batch of appeals led by Pr. CIT v. Praveen Sawhney, the Delhi High Court examined whether the limitation period for completing assessment under Section 153B could be extended due to a reference made to Swiss authorities under the DTAA. 

The Tribunal had quashed the assessment as time-barred, holding that the reference itself was invalid since it pertained to a period not covered under the amended DTAA.

The High Court upheld this reasoning, emphasizing that only a valid reference can trigger exclusion of time. An invalid or legally unsustainable reference cannot extend statutory limitation. 

The judgment reinforces strict interpretation of limitation provisions and underscores that procedural shortcuts cannot cure jurisdictional defects.