https://www.taxtmi.com/caselaws?id=211792 The Tribunal allowed the appeals of the assessee, setting aside the orders under sections 195, 201(1), and 201(1A) as invalid. The Tribunal concluded that no order under these sections can be passed if the revenue has not taken action against the payee within the prescribed time limit for initiating proceedings under section 147. Since no action was taken within the specified timeframe, the orders were deemed invalid. The Tribunal did not address the nature of payments or DTAA provisions due to the invalidity of the orders. en-us Fri, 24 Feb 2012 00:00:00 +0530 Thu, 21 Sep 2017 11:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=211792 The Tribunal allowed the appeals of the assessee, setting aside the orders under sections 195, 201(1), and 201(1A) as invalid. The Tribunal concluded that no order under these sections can be passed if the revenue has not taken action against the payee within the prescribed time limit for initiating proceedings under section 147. Since no action was taken within the specified timeframe, the orders were deemed invalid. The Tribunal did not address the nature of payments or DTAA provisions due to the invalidity of the orders. Case-Laws Income Tax Fri, 24 Feb 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=211792