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 procuremen

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