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2023 (3) TMI 1194 - AT - Income TaxValidity of order u/s 206C(1C)/206C(6A) - Period of limitation - whether order barred by limitation as it was passed beyond the reasonable period of time? - non collection of taxes at source (TCS) on receipt of payments made by lessees, licensees or the right holders in form of royalties and related compensatory and other amounts - whether in the absence of any specific time period specified in the Act can an order be passed u/s 206 of the Act at any time or there should be a reasonable limitation of time? - HELD THAT:- In the case on hand admittedly the order u/s 206C(1C)/206C(6A) assessment year 2009-10 was passed on 29.03.2016 which is admittedly beyond the period of four years from the end of the assessment year 2009-10. Order passed by the ITO(TDS), Moradabad u/s 206C(1C)/206C(6A) dated 29.03.2016 is barred by limitation and the same is quashed. Decided in favour of assessee.
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