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    <title>2019 (11) TMI 1241 - ITAT CHENNAI</title>
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    <description>Limitation for orders under sections 201(1) and 201(1A) was analysed by applying section 201(3) for the relevant years, with exclusion of the writ stay period under Explanation 1(ii) to section 153 and the time allowed for reply; on that basis, the orders for the earlier assessment years were treated as time-barred. Payments made by a third party administrator to hospitals for settlement of medical claims were treated as consideration for medical and professional services, so section 194J applied despite the agency arrangement. Interest under section 201(1A) was linked to the actual tax shortfall and, where deductees had paid advance tax, computation was confined to the balance shortfall up to filing of returns.</description>
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      <description>Limitation for orders under sections 201(1) and 201(1A) was analysed by applying section 201(3) for the relevant years, with exclusion of the writ stay period under Explanation 1(ii) to section 153 and the time allowed for reply; on that basis, the orders for the earlier assessment years were treated as time-barred. Payments made by a third party administrator to hospitals for settlement of medical claims were treated as consideration for medical and professional services, so section 194J applied despite the agency arrangement. Interest under section 201(1A) was linked to the actual tax shortfall and, where deductees had paid advance tax, computation was confined to the balance shortfall up to filing of returns.</description>
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