The revenue initiated a reference to Swiss Tax Authorities under Exchange Information Article 26 of Indo-Swiss DTAA on 14-11-2012. The Assessing Officer invoked clause (ix) of the Explanation to section 153B and passed assessment orders on 27-2-2015. On appeal, the assessee challenged the assessment orders on the ground of being barred by limitation.   Allowing the appeal the  Tribunal held that the amending protocol of the Indo-Swiss DTAA was signed on 30-8-2010. Article 26 would be effective for the exchange of information that relates to the following fiscal year commencing from 1-4-2011; thus, no request could be made under Article 26 (which was earlier numbered as Article 24) of the Indo-Swiss DTAA after 30-8-2010, as said article ceased to exist after 30-8-2010. Thus, where the Assessing Officer made reference for exchange of information to Switzerland tax authorities on 14-11-2012, the period of limitation could not be extended under Explanation (ix) to section 153B to frame an assessment based on such reference. Accordingly, the orders were quashed on the ground of limitation.  (AY. 2006-07 to 2011-12)