Sec. 206C Orders passed after reasonable period are void despite no limitation period

ITO Vs Eid Mohammad Nizamuddin (ITAT Jaipur) A consistent view has been taken by the various Hon’ble High Courts on this issue that when no limitation is provided in the statute then a period of four years is considered as reasonable for passing the order U/s 201(1)/201(1A) of the Act. The provisions of Section 206C of the Act are analogous and a measure for compliance of collection of tax at source as a similar measure for compliance of deduction of tax at source is provided U/s 201 of the Act. The department has accepted those decisions and consequently brought amendment to the provis...