Reasonable time limit applies to section 201 proceedings against a non-resident deductee where no express limitation is prescribed.

Orders under section 201 of the Income-tax Act concerning a non-resident deductee are not left open-ended merely because the statute does not prescribe an express limitation period. The Court applied the principle that, in the absence of a specific statutory time limit, initiation and completion of such proceedings must still occur within a reasonable time. On that basis, the issue of limitation was decided in favour of the assessee and against the Revenue.

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Issues: Whether orders under section 201 of the Income-tax Act, 1961, in relation to a non-resident deductee, were barred by limitation for want of a prescribed statutory time limit.

Analysis: The substantial questions turned on the applicability of a reasonable time limit for initiating and completing proceedings under section 201 where the deductee was a non-resident and the statute did not prescribe an express limitation period. The questions were treated as covered by the earlier decision relied upon by the Court.

Conclusion: The issue was answered in favour of the assessee and against the Revenue.

Ratio Decidendi: In proceedings under section 201 concerning a non-resident deductee, where no express limitation period is prescribed, action must still be taken within a reasonable time.

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