Circular No. 15 of 2017 [Dated 21st April, 2017]
Subject: Clarification on removal of Cyprus from the list of jurisdictional areas under Section 94-A of the Income Tax Act, 1961
Cyprus was specified as a “notified jurisdictional area” (NJA) under Section 94-A of the Income Tax Act, 1961 vide Notification N0. 86/2013 dated 01-11-2013. The said Notification No. 86/2013 was subsequently rescinded vide Notification No. 114 dated 14-12-2016 and Notification No. 119 dated 16-12-2016 with effect from the date of issue of the notification.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 01-11-2013. For removal of doubts, it is hereby clarified that Notification No. 86/2013 has been rescinded with effect from the date of issue of the said notification, thereby, removing Cyprus as a notified jurisdictional area with retrospective effect from 01-11-2013.
Ministry of Finance