Prior to amendment, withholding tax proceedings under Section 201 of the Income-tax Act have to be initiated within a reasonable period of four years

ACIT v. Catholic Relief Services (ITAT DELHI) Withholding tax proceedings under Section 201 of the Income-tax Act, 1961  were barred by limitation, since it has been initiated beyond a reasonable period of four years. Further the Tribunal held that in the absence of period of limitation under Section 201 of the Act prior to an amendment2, a reasonable time period was to be read into it, which was within 4 years from the end of the relevant Financial Year. INCOME TAX APPELLATE TRIBUNAL, DELHI ITA No. 2742 to 2744/Del/2011 Assessment Years:- 2003- 04 to 2005- 06 Assistant Commissioner of Incom...