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TMI Blog2020 (2) TMI 1557X X X X Extracts X X X X X X X X Extracts X X X X ..... ELD THAT:- There is no dispute in the instant case that payment for purchase of software was made by the assessee during the financial year 2009-10 relevant to A.Y 2010-11. Hence, six years from the end of the financial year would expire on 31-03-2016, which would be the last date for framing the assessment u/s. 201(1) of the Act in terms of pre-amended provisions of s. 201(3)(ii) - This section w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... against the order passed by the DCIT, International Taxation-2(2), Chennai (AO) u/s. 201(1) 201(1A) of the Income Tax Act, 1961 (hereafter the Act ) dated 31.03.2017 for the Assessment Year (A.Y) 2010-11. 2. We have heard the rival submissions and perused the material available on record. The Ld. AO framed the assessment u/s. 201(1) and 201(1A) of the Act on 31-3-2017 treating the assessee a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessee during the financial year 2009-10 relevant to A.Y 2010-11. Hence, six years from the end of the financial year would expire on 31-03-2016, which would be the last date for framing the assessment u/s. 201(1) of the Act in terms of pre-amended provisions of s. 201(3)(ii) of the Act. This section was later amended w.e.f 01-10-2014 substituting six years with seven years. We find that the th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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