Appellate Tribunal admitted additional grounds on limitation .Referred Special Bench  Mahindra & Mahindra Ltd  v.Dy.CIT (2009) 122 TTJ 577 (2010) 122 ITD 216  (SB )( Mum) (Trib)  affirmed in DIT(IT) v.  Mahindra & Mahindra Ltd (2014) 365 ITR 560 (Bom) (HC). The AO passed the order dt 6-2-2014 where as the order should have been passed on or before 31-03 2013 i.e. within one year from the end of the financial year in which proceedings u/s 201 are initiated. Tribunal held that since, the order is beyond the period of limitation the same is void ab initio and subsequent proceeings arising there form are vitiated. The departmental representative argued that the time limit specified in S. 201(3) & 201(4) for passing orders does not apply to cases where payments are made to non-residents.  Allowing the appeal and additional grounds the Tribunal held that in cases of payments made to non-residents also an order passed after one year from the end of the financial year in which the proceedings were initiated is void ab initio and liable to be quashed.As the order passed by the AO u/s 201(1) and 201(IA) is held to be void abinitio, the subsequent proceedings arising therefrom are vitiated and the appeals of the revenue are dismissed. (ITA Nos.1669, 1670 & 1671/PUN/2014, dt. 05.04.2019) (AY. 2008-09, 2009-10, 2010-11)