Initiation of proceedings u/s 201(1) beyond four years is time barred

Google India Pvt. Ltd Vs DCIT (ITAT Bangalore) Held that show cause notice to initiate proceedings u/s. 201(1) is issued on 20.11.2012 which is beyond four years with respect to assessment years 2007-08 & 2008-09. Accordingly, interest levied u/s 201(1A) unsustainable. Facts- The assessee has entered into Google Adword Program Distribution Agreement dated 12.12.2005 with Google Ireland Ltd. (GIL). As per the agreement, the assessee is appointed as a non-exclusive authorized distributor of Adword Programs to the advertisers in India. Accordingly, the assessee is liable to pay distribution f...