Reasonable time limit applies in absence of a specific legislative timeframe for Section 201 orders

CIT Vs Mphasis Ltd (Karnataka High Court) In the recent judgment of CIT Vs Mphasis Ltd, the Karnataka High Court addressed the issue of the time limits applicable to proceedings under Section 201 of the Income Tax Act, particularly in cases involving non-residents. The appeal was filed by the revenue challenging an order from the Income Tax Appellate Tribunal (ITAT) which had ruled that the proceedings were barred by limitation due to the application of a “reasonable time limit,” even though Parliament had not specified a time limit for such cases. The core issue was whether the IT...