Assessee was incorporated as a Special Purpose Vehicle and its parent company a Dubai based company ,  The AO held that assessee failed to discharge its obligation to make TDS u/s 195 and passed an order dated 3.3.2014 because the assessee has shown certain amount as ‘architectural fee’ under capital work in progress which was remittance made to parent company.  On appeal the CIT(A) held that  the time limit for initiating proceedings under section 201(1) and 201(IA) was four years from the end of the financial year in which the aassessee was required to deduct tax at source , hence the order was invalid .  The Tribunal affirmed the order of the Tribunal . Tribunal also held that  alleged laps was committed in the financial year 2005-06  which ended on 3-3-2016 . The order was passed on 3-3-2024  which is beyond period of seven years .  Followed CIT v. Acer India (P) Ltd (2022) 448 ITR 417/ 286 Taxman 570 ( Karn)( HC)     (AY. 2006-07)