TDS order passed beyond four-year time limit u/s 201(1) was Invalid

Indoworth India Ltd Vs ACIT (TDS) (ITAT Nagpur)

Conclusion: AO passed TDS order issued for non–deduction of TDS and interest thereon u/s 201(1) and 201(1A) was beyond the four-year limit and the same was barred by limitation under section 201(1) was invalid.

Held: Assessee challenged orders by CIT (Appeals) for the assessment year 2012–13 and 2013–14, uploading order under section 201(1A) passed by the ACIT (TDS), Nagpur. Registry had pointed out a delay of 218 days in filing the present appeal before the Tribunal. Tribunal opined that

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