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2023 (12) TMI 91 - ITAT MUMBAI
TCS of u/s. 206C(1) and interest u/s. 206C(7) - period of limitation - notice issued after 4 years period - HELD THAT:- Admittedly the assessment year involved in this cases A.Y. 2012- 13 and four years ends on 31-03-2016. However the show cause notice was issued by the A.O. on 27-06-2017 and order was passed on 26-07-2017 which is beyond 4 years. Therefore the order passed by the A.O. is construed to be an order passed after the period of limitation, the same is not maintainable in law and the same is liable to be quashed.