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2020 (3) TMI 1460 - AT - Income TaxLimitation period for initiating action u/s 201(1) and 201(1A) - non deduction of TDS u/s 195 on payments made to international telecom operators - HELD THAT:- The Hon’ble Jurisdictional High Court in the case of UB Electronic Instruments Ltd. (2014 (12) TMI 635 - ANDHRA PRADESH HIGH COURT) has considered that there is no limitation period prescribed for initiating action u/s 201(1) and 201(1A) of the Act, but after considering case law on the subject clearly held that 4 years is to be treated as the reasonable period within which any penal action can be initiated against the assessee and failure to initiate steps within that period would disable the department to proceed against the assessee. This decision has been relied upon by the CIT(A) to grant relief to the assessee. Since the decision relied upon by the CIT(A) is of jurisdictional High Court, this Tribunal is bound to follow - Decided against revenue.
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