Tribunal allowed the additional grounds and held that with effect from April 1, 2010 a time limit of two years from the end of the financial year in which the statements of tax deduction at source were filed has been provided for passing of orders under section 201(1) and (1A). The statements of tax deduction at source had been filed on March 31, 2014. The order under section 201(1) and (1A) having been passed on March 30, 2015 was beyond the period of limitation and was liable to be quashed. Relied on Tata Teleservices v. UOI  (2016) 385 ITR 497 (Guj.)(HC). For the assessment year 2010-11 matter remanded to CIT (A) to pass speaking order.   (AY. 2012-13, 2013-14)