The first three quarterly TDS statements were filed during financial year 2008-09, whereas the order under section 201(3) was passed on 15 June 2012. The Court held that since TDS statements are required to be filed quarterly under rule 31A, each quarterly filing constitutes a separate compliance period and provides an independent starting point for computing limitation under section 201(3). The order relating to the first three quarters, having been passed beyond two years from the end of the financial year in which the respective statements were filed, was barred by limitation. However, the fourth-quarter statement was filed in financial year 2009-10, and the order relating thereto was within the prescribed period; the demand for that quarter was therefore sustained. (AY. 2009-10)