The Assessee argued that the proceedings under Section 201(1) and 201(1A) were time-barred as they were initiated beyond a reasonable period of four years from the end of the relevant financial year. The Revenue maintained that there was no specific time limit prescribed for initiating proceedings under Section 201(1) and 201(1A) in cases involving non-resident payees. The Tribunal held that the proceedings under Section 201(1) and 201(1A) were not time-barred. That there is no specific time limit prescribed for initiating such proceedings in cases involving non-resident payees. Moreover, that the determination of a “reasonable time” limit depended on the facts and circumstances of each case. (AY. 2003 to 2010-11)