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2018 (2) TMI 179 - AT - Income TaxTDS u/s 194C - non deduction of tds - Assessee in default under the provisions of Sec. 201(1) and 201(1A) - period of limitation - Held that:- Keeping in view the judgment of the Hon’ble High Court of Bombay in the case of Director of Income tax (International taxation) Vs. Mahindra & Mahindra Ltd. (2014 (7) TMI 265 - BOMBAY HIGH COURT) and finding ourselves to be in agreement with the view taken by the Tribunal in the case of the assessee for the aforementioned years, therefore, are of the considered view that the order passed by the A.O under Sec. 201(1A) as on 28.03.2011 being substantially beyond the period of one year from the end of the financial year in which the proceedings under Sec. 201(1)/201(1A) were initiated, therefore, the respective orders passed by the A.O U/ss. 201(1)/201(1A) are clearly barred by limitation. - Decided in favour of assessee.
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