Where payments towards External Development Charges (EDC) were made during financial year 2015-16, the limitation of seven years prescribed under section 201(3) expired on 31-3-2023 and therefore the order passed thereafter treating the assessee as an assessee in default under sections 201(1) and 201(1A) was time-barred. The contention of the Revenue that such action was saved by section 153(6)(i) pursuant to liberty granted by the High Court in earlier proceedings was rejected, as the liberty to proceed further was expressly subject to action being taken “in accordance with law” and did not dilute or override the statutory limitation contained in section 201(3). The earlier judgment merely clarified the applicable TDS provision and did not contain any finding or direction enabling initiation of proceedings beyond limitation. Accordingly, the impugned order and consequential notice were quashed and set aside. (AY. 2016-17).