Assessee-company paid certain amount towards consultancy charges to Singapore based company.  Assessing Officer held that payments made by assessee were fees for technical services (FTS) and since assessee had not deducted tax at source under section 195 an order was passed under section 201(1) and 201(1A) on 6-3-2014. CIT(A) up held the order of the Assessing Officer. Order of CIT(A) is up held by the Tribunal. On appeal the Court held that   since transaction or payment related to financial years 2006-07, 2007-08, 2008-09 and  order under section 201(1) and 201(1A) was passed beyond period of four years, same is  barred by limitation. (AY. 2007-08 to 2009-10)