TDS Default Order Time-Barred as Limitation Must Be Computed Quarter-Wise, Not Annually

CIT (TDS) Vs Vodafone Cellular Ltd. (Bombay High Court) The Bombay High Court held that limitation under Section 201(3) for passing an order under Section 201(1) is to be computed from the end of the financial year in which the TDS statement under Section 200 is filed. Since, under Rule 31A, TDS statements are required to be filed quarterly, the limitation must necessarily be computed quarter-wise and not on a cumulative annual basis. Accordingly, where TDS statements for the first three quarters were filed in FY 2008-09, the order passed on 15 March 2012 was beyond the prescribed limitation...