https://www.taxtmi.com/caselaws?id=193693 HC held that, despite the absence of an express limitation period for initiating proceedings under Sections 195 and 201 regarding payments to non-residents, such proceedings must be commenced within a reasonable time. The revenue's reliance on administrative convenience and a circular justifying no limitation, on the ground of difficulty in recovering tax from non-residents, was rejected, following SC and earlier HC precedent. The court emphasized that indefinite exposure would impose an unduly harsh burden on resident payers to preserve records indefinitely. Finding the initiation of proceedings to be time-barred and unreasonable, HC quashed the impugned notices and allowed the writ petition. en-us Mon, 19 Dec 2016 00:00:00 +0530 Thu, 27 Nov 2025 10:51:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=193693 HC held that, despite the absence of an express limitation period for initiating proceedings under Sections 195 and 201 regarding payments to non-residents, such proceedings must be commenced within a reasonable time. The revenue's reliance on administrative convenience and a circular justifying no limitation, on the ground of difficulty in recovering tax from non-residents, was rejected, following SC and earlier HC precedent. The court emphasized that indefinite exposure would impose an unduly harsh burden on resident payers to preserve records indefinitely. Finding the initiation of proceedings to be time-barred and unreasonable, HC quashed the impugned notices and allowed the writ petition. Case-Laws Income Tax Mon, 19 Dec 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=193693