https://www.taxtmi.com/caselaws?id=181764 Proceedings under section 201 must be initiated and concluded within a reasonable time; applying a four-year outer limit on the facts, the Tribunal held the order treating the assessee as in default under section 201(1) and charging interest under section 201(1A) to be time-barred and invalid. Payments to the non-resident lead manager and related parties for the Euro issue were not fees for technical services under the India-UK treaty because the services did not make available technical knowledge, experience, skill, know-how or processes to the assessee. As the treaty position prevailed, no tax was deductible under section 195(1). en-us Wed, 08 Jun 2005 00:00:00 +0530 Wed, 18 Dec 2024 13:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=181764 Proceedings under section 201 must be initiated and concluded within a reasonable time; applying a four-year outer limit on the facts, the Tribunal held the order treating the assessee as in default under section 201(1) and charging interest under section 201(1A) to be time-barred and invalid. Payments to the non-resident lead manager and related parties for the Euro issue were not fees for technical services under the India-UK treaty because the services did not make available technical knowledge, experience, skill, know-how or processes to the assessee. As the treaty position prevailed, no tax was deductible under section 195(1). Case-Laws Income Tax Wed, 08 Jun 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=181764