Allowing the appeal the Tribunal held that the transaction took place on April 24, 2010, in the financial year 2010-11 and the Assessing Officer passed the order on March 22, 2018 by issue of notice under section 195 on September 18, 2017. Thus, the action taken by the Assessing Officer was more than six years from the end of the financial year in which the transaction took place and the proceedings initiated by the Assessing Officer were barred by limitation. (AY.2011-12)
Sravan Shipping Services (P.) Ltd. v. Dy. CIT (IT) (2021) 86 ITR 6 (SN) (Vishakha)(Trib.)
S. 201 : Deduction at source-Failure to deduct or pay-Non-resident-Time-Notice issued more than six years from end of financial year in which transaction took place-Proceedings barred by limitation. [S. 195, 201(1A)]