Order U/s. 201(1) & 201(1A) after one year in case of non-residents was void-ab-initio

Atlas Copco (India) Limited Vs DCIT (ITAT Pune) Conclusion: Where payments in the nature of royalty/fee for technical services (FTS) were made to non -residents, an order u/s. 201 passed after one year from the end of the financial year in which the proceedings were initiated was void ab initio and liable to be quashed. Held: During the relevant financial years, assessee made payments to various foreign companies  and the same were made towards procurement of software license, software maintenance charges, testing charges, website maintenance charges, personal management charges, software exp...