Prior to amendment, withholding tax proceedings under Section 201 of the Income-tax Act have to be initiated within a reasonable period of four years

ACIT v. Catholic Relief Services (ITAT DELHI)

Withholding tax proceedings under Section 201 of the Income-tax Act, 1961  were barred by limitation, since it has been initiated beyond a reasonable period of four years. Further the Tribunal held that in the absence of period of limitation under Section 201 of the Act prior to an amendment², a reasonable time period was to be read into it, which was within 4 years from the end of the relevant Financial Year.

INCOME TAX APPELLATE TRIBUNAL, DELHI

ITA No. 2742 to 2744/Del/2011

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