https://www.taxtmi.com/caselaws?id=25803 Under the TDS recovery scheme, liability arises immediately when tax is not deducted under section 195 or, after deduction, is not paid under section 200, and a person may be treated as an assessee in default under section 201 without any separate demand order. Section 231 is read as containing two distinct limbs: for default-based recovery, limitation begins from the last day of the financial year in which the default occurred, not from the date of a later section 201 order. The commentary distinguishes the old Act because it lacked this second limb and notes that legislative materials support this interpretation. en-us Wed, 25 Feb 1987 00:00:00 +0530 Mon, 01 Feb 2010 10:27:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=25803 Under the TDS recovery scheme, liability arises immediately when tax is not deducted under section 195 or, after deduction, is not paid under section 200, and a person may be treated as an assessee in default under section 201 without any separate demand order. Section 231 is read as containing two distinct limbs: for default-based recovery, limitation begins from the last day of the financial year in which the default occurred, not from the date of a later section 201 order. The commentary distinguishes the old Act because it lacked this second limb and notes that legislative materials support this interpretation. Case-Laws Income Tax Wed, 25 Feb 1987 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=25803