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1969 (2) TMI 59 - CALCUTTA HIGH COURTAssessee is a resident-company - failure to deduct tax from the payment made to a non-resident - order u/s 18(7) passeddeeming the assessee to be an assessee in default - person who is to deduct the tax at the time of making payment to a non-resident is not an agent and is not deemed to be an assessee for all the purposes of IT Act - such order cannot be treated as assessment order - period of limitation prescribed u/s 34(3) not applicable to impugned order
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