Limitation under section 201(1) bars belated tax proceedings; the saving proviso to section 201(3) cannot revive time-barred matters.

Proceedings under section 201(1) for earlier assessment years were held to be time-barred because the first effective show-cause notice came after the limitation period had already expired, and earlier communications were treated only as information requests. The saving proviso to section 201(3) was held to apply only to proceedings that were actually pending within its stated window; it did not revive matters already barred by time. The Tribunal's view that the initiation was beyond the permissible period was therefore left undisturbed, and the Revenue's challenge failed.

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Issues: Whether initiation and completion of proceedings under section 201(1) of the Income-tax Act, 1961 for the relevant assessment years were barred by limitation, and whether the proviso to section 201(3) saved the proceedings.

Analysis: The show-cause notice issued on 02.12.2010 was treated as the first proper notice under section 201(1), earlier letters being regarded only as requests for information. On the facts, the period for initiating proceedings for assessment years 2000-01 to 2004-05 had already expired before the insertion of section 201(3), and the proviso permitting completion of proceedings for financial years commencing on or before 01.04.2007 applied only to pending proceedings and did not revive time-barred matters. The Court found no substantial question of law arising from the Tribunal's view that the proceedings were initiated beyond the permissible period.

Conclusion: The proceedings under section 201(1) for the relevant years were barred by limitation, and the Revenue's challenge failed.

Final Conclusion: The dismissal of the appeal left undisturbed the Tribunal's quashing of the demand raised under section 201(1) for the relevant assessment years.

Ratio Decidendi: A belated show-cause notice cannot revive proceedings under section 201(1) where limitation had already expired, and the saving proviso to section 201(3) protects only proceedings that were actually pending within its temporal window.

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