Order must be passed in reasonable time in absence of prescribed statutory time limit with reference to collection of taxes

Adani Enterprise Ltd. Vs DCIT (ITAT Ahmedabad) We notice that no time limit has been prescribed for passing order under s.206C of the Act. The CIT(A) has assumed that in the absence of statutory time limit provided, the provisions of Section 201(3) of the Act providing time limit for deduction of tax at source can be parallelly adopted for the purposes of viewing what is reasonable time. We do not see much force in such presumption especially in the matter of limitation. The limitation prescribed under one provision of the Act cannot be applied straightway to some other provisions of the Act. ...