TMI Blog2023 (1) TMI 730X X X X Extracts X X X X X X X X Extracts X X X X ..... to avoid any further question, which may arise on limitation, we confirm the impugned judgment and order passed by the High Court [ 2022 (2) TMI 345 - BOMBAY HIGH COURT ] quashing and setting aside the order u/s 201 we also direct that the matter be remitted to the AO(TDS) at the stage of issuance of show cause notice u/s 201 so that after the decision of the High Court in the pending Appeal, the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... at in the present case, notice under Section 201 of the Income Tax Act, 1961 was issued much prior to the ITAT decided against the Department, which was for the AY 2014-2015. It is submitted that the appeal against the final decision of the ITAT for AY 2014-2015 is pending before the High Court. It is submitted that even the judgment for AY 2010-2011 which is followed subsequently while deciding t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... enue and Shri Jehangir D. Mistry, learned Senior Advocate, appearing on behalf of the assessee and in the facts and circumstances of the case and considering the fact that the liability of the recipient in the subject-matter of Appeal before the High Court and to avoid any further question, which may arise on limitation, we confirm the impugned judgment and order passed by the High Court quashing ..... X X X X Extracts X X X X X X X X Extracts X X X X
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