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2012 (3) TMI 188 - AT - Income TaxNon deduction of TDS - Period of limitation u/s 201(3) - assessee did not deduct tax at source from the salary paid to the aforesaid employees within the prescribed time, the AO treated the assessee company in default in terms of provisions of section 201(1) of the Act and accordingly, raised demand u/s 201(1) and 201(1A) of the Act- Assessee contented that as he paid the tax and tax thereon voluntarily but the acceptance of the liability would not extend the period of limitation nor would it extend the reasonable time that is postulated by the scheme of the Income-tax Act - Held that :- answer to the question of limitation is in the affirmative in favour of the assessee and against the revenue - initiation of proceedings under section 201 of the Act against the assessee in respect of the assessment year 1990-91 was barred by limitation having been initiated beyond a reasonable period of time of four years - proceedings under section 201/201(1A) of the Act, can be initiated only within three years from the end of the assessment year or within four years from the end of the relevant financial year.
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