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2018 (4) TMI 450 - AT - Income TaxValidity of order u/s 201(1) - period of limitation - Held that:- As per provisions contained in Finance (No.2) Act, 2014, effective from 01.04.2010, the order u/s 201 was required to be passed within two years from the end of financial year in which statement is filed or four years from the end of financial year in which payment is made or credit is given in any other case. But, in the instant case, TDS verification letter / notice was issued on 23.01.2015 and order u/s 201(1) was passed on 30.03.2015 and 05.03.2015 for AYs 2008-09 and 2010-11 respectively which are hopelessly barred by limitation as the same were required to be passed within a period of two years or four years as the case may be, as amended provisions of Finance (No.2) Act, 2014 relied upon by AO as well as CIT (A) are not applicable in these cases. Assessment order passed by AO is beyond the period of limitation, which is without jurisdiction - Decided in favour of assessee.
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