Income Tax Authorities have to initiate proceedings u/s 201 within four years

Issue before court: Whether proceeding u/s 201 initiated against assessee is barred by limitation. Brief facts: Assessee Company was sought to be as assessee in default for the FY 2002-03 and AY 2003-04. Hence addition was made accordingly and demand was raised. The assessee’s position was that treating the assessee company as one in default irrespective of past assessment years this was arrested that its returns were financed much earlier and that the action under Section 201 is belated. CIT (A) followed decision of CIT NHK Japan Broadcasting Corporation (2008) 305 ITR 137 (Del) and CIT vs...