2018 (4) TMI 200 - SCH - Income Tax

Validity of the action initiated u/s 201(1) and 201(1A) - non-deduction of tax at source for periods earlier than four years prior to 31st March, 2011 - Held that - SLP dismissed. HC order confirmed 2016 (8) TMI 509 - DELHI HIGH COURT HC has held Circular 5 of 2010 of CBDT clarifying that the proviso to Section 201(3) of the Act was meant to expand the time limit for completing the proceedings and passing orders in relation to pending cases . The said proviso cannot be interpreted to initiate proceedings for declaring an Assessee to be an Assessee in default under Section 201 for a period earlier than four years prior to 31st March, 2011. The notices impugned in the present petitions issued by the Department seeking to initiate proceedings against the Petitioners for declaring them to be Assessee in default under Section 201(3) hereby quashed. - Decided in favour of assessee.