SECTION 94A OF THE INCOME-TAX ACT, 1961 – SPECIAL MEASURES IN RESPECT OF TRANSACTIONS WITH PERSONS LOCATED IN NOTIFIED JURISDICTIONAL AREA – CLARIFICATION ON REMOVAL OF CYPRUS FROM LIST OF NOTIFIED JURISDICTIONAL AREAS UNDER SAID SECTION
CIRCULAR NO.15 OF 2017 [F.NO.500/002/2015-FT&TR-III], DATED 21-4-2017
Cyprus was specified as a “notified jurisdictional area” (NJA) under section 94A of the Income-tax Act, 1961 vide Notification No. 86/2013 dated, 1-11-2013. The said Notification No. 86/2013 was subsequently rescinded vide Notification No. 114 dated, 14-12-2016 and Notification No. 119 dated, 16-12-2016 with effect from the date of issue of the notification.
2. It has been brought to notice of the Central Board of Direct Taxes that in some cases a view has been taken by the Income-tax authorities that the rescission of Notification No. 86/2013 was not with retrospective effect from 1-11-2013. For removal of doubts, it is hereby clarified that Notification No. 86/2013 has been rescinded with effect from the date of issue of the said notification, thereby, removing Cyprus as a notified jurisdictional area with retrospective effect from 1-11-2013.