Court held that for the assessment years 1998-99 to 2005-06, the proceedings under section 201(1) and (1A) of the Income-tax Act, 1961 had been initiated after a period of four years. Accordingly held to be barred by limitation . Followed Therefore, they could not be held to have been initiated within a reasonable time and consequently, the proceedings could not be sustained in the eye of law. In State of Punjab v. Bhatinda District Co-operative Milk Producers Union Ltd. (2007) 11 SCC 363 has held that four years would be a reasonable period of time for initiating action, in a case where no limitation is prescribed. ( AY.1998-99 to 2005-06)
DIT(IT) v. Executive Engineer Bangalore Water Supply and Sewerage Board (2020) 428 ITR 294/ 194 DTR 364 (Karn)(HC)
S. 201 : Deduction at source – Failure to deduct or pay -Short deduction -Limitation – Proceedings must be initiated within reasonable time — Proceedings initiated after four years — Barred by Limitation [ S.201(1) , 201(IA) ]