https://www.taxtmi.com/caselaws?id=353448 Proceedings under Section 201 were held time-barred for earlier financial years because, in the absence of a prescribed limitation, action had to be initiated within four years; the notice issued beyond that period could not sustain liability for those years, and the consequential orders were cancelled. For the later financial years, the assessee failed to substantiate that SAP and intranet payments were mere reimbursements, as no underlying agreements, debit notes, or cost workings were produced. The Tribunal therefore treated the SAP-related remittances as royalty under the Act and the applicable treaty, making tax deductible at source under Section 195, and upheld the demand and interest for those years. en-us Wed, 25 Oct 2017 00:00:00 +0530 Thu, 04 Jan 2018 09:23:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=353448 Proceedings under Section 201 were held time-barred for earlier financial years because, in the absence of a prescribed limitation, action had to be initiated within four years; the notice issued beyond that period could not sustain liability for those years, and the consequential orders were cancelled. For the later financial years, the assessee failed to substantiate that SAP and intranet payments were mere reimbursements, as no underlying agreements, debit notes, or cost workings were produced. The Tribunal therefore treated the SAP-related remittances as royalty under the Act and the applicable treaty, making tax deductible at source under Section 195, and upheld the demand and interest for those years. Case-Laws Income Tax Wed, 25 Oct 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=353448