Held that the amendment made in S. 201(3) by Finance (No. 2) Act, 2014 is effective from 1st Oct., 2014; since Form No. 26Q for the last quarter was filed in the financial year ending on 31st March, 2012, the limitation provided for passing order under s. 201(1) for asst. yr. 2011-12 had already expired on 31st March, 2014 i.e., prior to s. 201(3) came to be amended by Finance (No. 2) Act of 2014 and, therefore, the order under S. 201(1) passed on 30th March, 2018 was barred by limitation. Followed Tata Teleservices v. UOI(2016) 284 CTR 337 / 132 DTR 1/ 385 ITR 497 (Guj) (HC),Oracle India (P) Ltd. v. Dy. CIT (2015) 126 DTR 146 / 376 ITR 411 (Delhi)(HC) (AY.2011-12)
Reebok India Co. v. JCIT (2022) 220 DTR 141 / 220 TTJ 871 (Delhi)(Trib)
S. 201 : Deduction at source-Failure to deduct or pay-Limitation for passing order-limitation provided for passing order under s. 201(1) for asst. yr. 2011-12 had already expired on 31st March, 2014 i.e., prior to s. 201(3) came to be amended by Finance (No. 2) Act of 2014-Order passed on 30th March, 2018 was barred by limitation. [S. 201(1), 201(3), Form 26Q4]