Assessee purchased an immovable property from a non-resident seller and paid consideration without deducting tax at source.  The Assessing Officer held the assessee as the assessee in default and levied tax liability of a certain amount under section 201(1) and interest liability of a certain amount under section 201(1A) of the Act.  Held that sellers had disclosed consideration received from the assessee in their respective returns, thus, assessee could not be held as assessee-in-default as per the retrospective effect of amended provisions of section 201(1), inserted in Finance (No. 2) Act, 2019. Proviso to section 201(1) wherein benefit as to non-deduction of tax by assessee in case deductees had disclosed payments received by them in their respective returns had also been extended to payments made to non-residents for removal of anomaly has retrospective effect, therefore, assessee could not be held as an assessee in default as per proviso to section 201(1) of the Act. On the facts the assessee sold the property on 17-9-2011 payees filed their return of income disclosing said amount to a tax on 30-7-2012, the interest amount levied upon the assessee under section 201(1A) should be calculated for the period from 7-10-2011 to 30-7-2012 till the date of filing of return by payees. Matter remanded.  (AY. 2012-13)