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 i

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