Swiss Bank deposits not taxable as exchange of info. prior to 01-04-2011 not covered by Article 26

INCOME TAX : Where Swiss Authorities had not provided any information to Revenue Authorities in India about assessee's bank account with HSBC, Geneva, Switzerland for assessment years i.e., A.Ys. 2006-2007 to 2011-2012 as such information could be provided as per Article 26 only from 1-4-2021, i.e., from Financial Year 2011-12, it could be said that there was no incriminating material available on record before Revenue to make addition,

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