2016 (6) TMI 1352

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..... limitation. The amended sub-section(3) of section 201 with effect from 1.10.2014 enlarges the period of limitation to seven years which, as held by this Court in the case of Tata Teleservices [ 2016 (2) TMI 414 - GUJARAT HIGH COURT] cannot be applied retrospectively. For such reason, the petitions are allowed. The impugned notices dated 15.9.2015 are quashed. Petitions disposed of accordingly. .....

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..... iry is time barred. Learned counsel for the petitioners would draw our attention to sub-section (3) of section 201 of the Act as it stood prior to the amendment made by the Finance Act, 2014 with effect from 1.10.2014 which reads as under: 201(3) No order shall be made under sub-section (1) deeming a person to be an assessee in default for failure to deduct the whole o .....

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..... r the Revenue. 3. The admitted facts emerging from the record are that as per sub-section (3) of section 201 which stood prior to 1.10.2014, the initiation of action for failing to deduct tax at source is barred by limitation. The amended sub-section(3) of section 201 with effect from 1.10.2014 enlarges the period of limitation to seven years which, as held by this Court in the cas .....

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