Section 201(3)(ii) Limitation not applicable to Non resident Assessee

ITO Vs Bata India Ltd. (ITAT Kolkata) There is no dispute on the basic fact that the Assessing Officer’s order herein dated 10.06.2009 passed u/s 201(1A) r.w.s. 195 of the Act has raised interest payment in issue of ₹1,02,545/- for the reason that it failed to pay the TDS deducted on royalty payments to the tune of ₹41,01,800/- on time. The CIT(A) has invoked Section 201(3)(ii) of the Act and holds that the assessee’s impugned default had been committed in FY 2002-03 and the Assessing Officer’s notice stood issued on 03.04.2009, the proceedings initiated herein are barred...