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2020 (7) TMI 307 - AT - Income TaxTDS u/s 195 - order passed u/s 201(1A) on failure pay the TDS deducted on royalty payments - Time barred proceedings - CIT(A) has invoked Section 201(3)(ii) and holds that the assessee's impugned default had been committed in FY 2002-03 and the AO's notice stood issued on 03.04.2009, the proceedings initiated herein are barred by limitation since instituted beyond a period of six years from the end of the relevant financial year - HELD THAT:- This is very very fair in stating that the assessee herein is not an Indian resident so as to be covered under the foregoing statutory provision describing limitation in initiation of the impugned proceedings. We therefore reverse the CIT(A)'s action holding the impugned proceedings as time barred. Assessing Officer's order dated 10.06.2009 stands restored as a necessary corollary. Revenue's appeal is allowed.
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