Pursuant to a survey under section 133A(2A), proceedings were initiated to treat the assessee as an assessee in default under section 201(1) and to levy interest under section 201(1A). The Tribunal held that a reasonable time-limit for initiating proceedings under section 201(1) is four years. Since the notices had been issued beyond four years from the end of the relevant financial years, the proceedings were barred by limitation. The orders passed under sections 201(1) and 201(1A) were accordingly quashed. The assessee explained that the delay of 218 days in filing the appeal occurred because its authorised representative had undergone heart surgery and was unable to attend to professional work. Hospital records and other supporting evidence were produced. The Tribunal held that the delay was supported by sufficient cause, there was no mala fide intention and, accordingly, condoned the delay  (AY. 2012-13 & 2013-14).