Time limit in respect of TDS under Section 201(3) applies to residents only

ACIT (Intl. Taxn) Vs Allscripts (India) Pvt. Ltd. (ITAT Ahmedabad) It is pertinent to note that Section 201(3) specifies the time limit in respect of TDS for residents only. The CIT(A) observed that the order dated 25.03.2019 is beyond four years in light of Hon’ble Delhi High Court decision in case of NHK Japan Broadcasting Corporation (Supra). The decision of Jurisdictional High Court referred by the CIT(A) is opt in present case as regards to limitation. Further on merit, the assessee before the AO as well as before the CIT(A) has given the details as well as agreement between the assesse...