https://www.taxtmi.com/caselaws?id=75616 Proceedings under sections 201 and 201A of the Income-tax Act must be initiated within a reasonable time, even though no express limitation period is prescribed. The Delhi High Court applied the earlier principle that four years from the end of the relevant financial year may be treated as the outer limit, drawing support from the time structure in section 153(1)(a). On the facts, the action had been commenced beyond both the three-year period from the end of the assessment year and the four-year period from the end of the financial year, so the proceedings were barred by time and unsustainable. en-us Thu, 15 Apr 2010 00:00:00 +0530 Tue, 18 Nov 2025 10:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=75616 Proceedings under sections 201 and 201A of the Income-tax Act must be initiated within a reasonable time, even though no express limitation period is prescribed. The Delhi High Court applied the earlier principle that four years from the end of the relevant financial year may be treated as the outer limit, drawing support from the time structure in section 153(1)(a). On the facts, the action had been commenced beyond both the three-year period from the end of the assessment year and the four-year period from the end of the financial year, so the proceedings were barred by time and unsustainable. Case-Laws Income Tax Thu, 15 Apr 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=75616