TMI Blog2020 (7) TMI 307X X X X Extracts X X X X X X X X Extracts X X X X ..... sued 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 there ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 50 lakhs as per the CBDT Circular No. 17/2019 dated 08.08.2019. Heard both the parties. Case file(s) perused. 2. It transpires at the outset that Revenue's sole substantive grievance seeks to restore its foregoing main appeal on the ground that it is an exceptional case involving audit objection. And also that this tribunal's earlier order dated 30.07.2018 invoked the Board's ear ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ) r.w.s. 195 of the Act has raised interest payment in issue of ₹1,02,545/- for the reason that it failed to pay the TDS deducted on royalty payments to the tune of ₹41,01,800/- on time. The CIT(A) has invoked Section 201(3)(ii) of the Act and holds that the assessee's impugned default had been committed in FY 2002-03 and the Assessing Officer's notice stood issued on 03.04.200 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f the COVID-19 pandemic and lockdown, the foregoing period needs to be excluded. For coming to such a conclusion, we rely upon the decision of the Co-ordinate Bench of the Mumbai Tribunal in the case of DCIT vs. JSW Limited in ITA No. 6264/Mum/2018 6103/Mum/2018, Assessment Year 2013-14, order dated 14th May, 2020. 4. This Revenue's MA No. 227/Kol/2019 as well the main appeal ITA 914/Kol/ ..... X X X X Extracts X X X X X X X X Extracts X X X X
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