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    <title>Appeal dismissed: destroyed records, inapplicability of TDS for years, proviso to Section 201 post-01.07.2012, delay bars claim</title>
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    <description>The HC affirmed the Single Judge&#039;s dismissal of the writ petition, holding the appellant&#039;s claim untenable because relevant records were destroyed and statutory TDS provisions were inapplicable for significant portions of the claim, rendering issuance of an accountant&#039;s certificate in Form 26A practically unenforceable. The court agreed the grievance for FY 2009-10 to 2012-13 did not attract the proviso to Section 201, which took effect on 01.07.2012, and upheld findings of default in non-deduction of tax. The HC also endorsed the Single Judge&#039;s view that the petition was time-barred by the decade-long delay. The court noted an ITAT remand for AY 2013-14 but observed no subsequent proceedings were placed on record.</description>
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    <pubDate>Wed, 12 Nov 2025 08:17:49 +0530</pubDate>
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      <title>Appeal dismissed: destroyed records, inapplicability of TDS for years, proviso to Section 201 post-01.07.2012, delay bars claim</title>
      <link>https://www.taxtmi.com/highlights?id=94102</link>
      <description>The HC affirmed the Single Judge&#039;s dismissal of the writ petition, holding the appellant&#039;s claim untenable because relevant records were destroyed and statutory TDS provisions were inapplicable for significant portions of the claim, rendering issuance of an accountant&#039;s certificate in Form 26A practically unenforceable. The court agreed the grievance for FY 2009-10 to 2012-13 did not attract the proviso to Section 201, which took effect on 01.07.2012, and upheld findings of default in non-deduction of tax. The HC also endorsed the Single Judge&#039;s view that the petition was time-barred by the decade-long delay. The court noted an ITAT remand for AY 2013-14 but observed no subsequent proceedings were placed on record.</description>
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      <pubDate>Wed, 12 Nov 2025 08:17:49 +0530</pubDate>
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