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2018 (4) TMI 991 - AT - Income TaxTDS u/s. 195 - assessee in default - order passed u/s. 201(1) and 201(1A) as barred by limitation - Held that:- The assessee was liable for withholding tax u/s. 195 of the Act in respect of payment made by it for managerial services fees. In the instant case, the financial year concerned is 2006-2007 and notice for initiating proceedings u/s 201(1) / 201(1A) was issued on 30.04.2014, i.e. more than seven years from the end of the financial year. The orders u/s 201(1) / 201(1A) was finally passed on 30.05.2016, which is more than eight years from the end of the financial year. Therefore, it cannot be stated in facts of this case, the order u/s 201(1) / 201(1A) was passed within a reasonable time and the prescription of limitation mentioned u/s 201(3) and (4) - the order passed u/s 201(1)/ 201(1A) was barred by limitation in the facts and circumstances of the case. - Decided in favour of assessee
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