Dismissing the appeal of the Revenue , the Court held that the deemed reasonable period of limitation is four years when no period of limitation is prescribed by statute – Held, yes – Whether where order under section 201(1) was passed by Assessing Officer beyond four years from end of relevant financial year, Tribunal was justified in setting aside said order . (AY. 2002 -03 , 2003 -04 )
Income-tax Officer, TDS v. Indian Oil Corporation Ltd( 2023) 334 CTR 999/ 156 taxmann.com 576/(2024) 296 Taxman 428 ( Pat)( HC)
S. 201 : Deduction at source – Failure to deduct or pay -Limitation- Oder under section 201(1) was passed by Assessing Officer beyond four years from end of relevant financial year, Tribunal was justified in setting aside the order .[ S. 201(1), 201(IA) , 260A ]