Limitation period of six years for passing order u/s 201(3) is effective only from 01.10.2014

Reebok India Company Vs J.C.I.T (ITAT Delhi) ITAT Delhi held that the limitation period is four years for passing assessment order in case of TDS statement not filed. Limitation period substituted to six years effective only from 01/10/2014. Facts- The assessee is engaged in the business of distribution of foot wear and apparels and sell its merchandise in India directly to independent retailers, often under distribution or franchise agreement. Based on the survey proceedings conducted u/s. 133A of the Income-tax Act, 1961 on the Ambience Group who are the owners and operators of malls where a...