The assessee purchased an immovable property from a non-resident seller and paid consideration for same without deducting tax at source . The Assessing Officer held assessee as assessee in default and levied tax liability of certain amount under section 201(1) and interest liability of certain amount under section 201(1A) of the Act . The Assessee contended that sellers had disclosed consideration received from assessee in their respective returns, thus, assessee could not be held as assessee-in-default as per retrospective effect of amended provisions of section 201(1), inserted in Finance (No. 2) Act, 2019. Order of AO is affirmed by CIT(A) . On appeal the Tribunal held that payee filed the return of income and disclosed the consideration in their respective returns and paid the taxes .  Proviso to section 201(1) inserted by the Finance( No. 2) Act , 2019 is retrospective as it removes statutory over sums paid to non-residents  . The Tribunal held that property was sold by the appellant on 17 th September  2011 and the return of income by two payee have been filed on 30 th July , 2012 . Accordingly the interest u/s 201(IA ) of the Act  has to be calculated for the period 7 th October , 2011 to 30 th July  2012  being the date of filing of the return by the two payees .   ( AY. 2012 -13 )