https://www.taxtmi.com/caselaws?id=254292 Proceedings for demand and levy of interest under Section 201 of the Income-tax Act, 1961 must be initiated within a reasonable period even though the provision prescribes no express limitation. The HC applied the statutory scheme and held that, like other time-bound actions under the Act, action for failure to deduct tax at source cannot be left open-ended. On the facts, a notice issued nearly seven years after the relevant assessment years was beyond a reasonable time, particularly where commercial and financial positions may change over time. The levy under Sections 201 and 201(1A) was therefore time-barred, and the Tribunal's view was upheld. en-us Wed, 12 Nov 2014 00:00:00 +0530 Fri, 09 Sep 2022 14:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=254292 Proceedings for demand and levy of interest under Section 201 of the Income-tax Act, 1961 must be initiated within a reasonable period even though the provision prescribes no express limitation. The HC applied the statutory scheme and held that, like other time-bound actions under the Act, action for failure to deduct tax at source cannot be left open-ended. On the facts, a notice issued nearly seven years after the relevant assessment years was beyond a reasonable time, particularly where commercial and financial positions may change over time. The levy under Sections 201 and 201(1A) was therefore time-barred, and the Tribunal's view was upheld. Case-Laws Income Tax Wed, 12 Nov 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=254292