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2019 (10) TMI 244 - AT - Income TaxDemand u/s 201(1)/(1A) for non-deduction of taxes on IUC - period of limitation - TDS u/s 194J - HELD THAT:- As decided in own case [2018 (3) TMI 1758 - ITAT MUMBAI] the time limit for initiation of proceedings u/s 201(1) in the hands of the present assessee for the assessment years under consideration has expired long back prior to insertion of sec. 201(3) by Finance Act No.2 of 2009. Proceedings have become time barred prior to 01-04-2007 and hence no fresh proceedings could be commenced for the impugned years by virtue of the proviso to sec. 201(3) of the Act. - Decided in favour of assessee.
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