2008 (4) TMI 182 - DELHI HIGH COURT

Failure to deduct tax at source – but assessee paid the required interest without disputing its liability – AO passed an order u/s 201(1) & 201(1A) treating the assessee as being in default – held that acceptance of liability will not by itself extend period of limitation - Held that action must be initiated within period of 4 years, where no limitation is prescribed as in section 201 - initiation of proceedings in 1999 in respect of the A.Y. 1990-91, is barred by limitation