https://www.taxtmi.com/caselaws?id=373578 Orders treating an assessee as in default under section 201 cannot be initiated after an unreasonable lapse of time for non-resident payments, and the Tribunal applied the jurisdictional High Court's four-year benchmark to hold the 2013 orders for the earlier assessment years barred by limitation. The payments to the non-resident were also held not to constitute fees for technical services or fees for included services, because the data and reports supplied did not make available technical knowledge, skill, or know-how enabling independent use by the recipient. As a result, the domestic withholding basis could not be sustained and the assessee was not liable to be treated as in default on that ground. en-us Fri, 11 Jan 2019 00:00:00 +0530 Thu, 07 Feb 2019 15:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=373578 Orders treating an assessee as in default under section 201 cannot be initiated after an unreasonable lapse of time for non-resident payments, and the Tribunal applied the jurisdictional High Court's four-year benchmark to hold the 2013 orders for the earlier assessment years barred by limitation. The payments to the non-resident were also held not to constitute fees for technical services or fees for included services, because the data and reports supplied did not make available technical knowledge, skill, or know-how enabling independent use by the recipient. As a result, the domestic withholding basis could not be sustained and the assessee was not liable to be treated as in default on that ground. Case-Laws Income Tax Fri, 11 Jan 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=373578