Section 201(3) amended WEF 01-10-2014 cannot be applied retrospectively

Eris Life Sciences (P) Ltd. Vs DCIT (High Court Gujarat)

As per sub-section (3) of section 201 which stood prior to 1.10.2014, the initiation of action for failing to deduct tax at source is barred by limitation. The amended sub-section(3) of section 201 with effect from 1.10.2014 enlarges the period of limitation to seven years which, as held by this Court in the case of Tata Teleservices cannot be applied retrospectively. Therefore, the notices issued by AO were quashed.

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