https://www.taxtmi.com/caselaws?id=787528 Whether the limitation under Section 201(3) is computed quarter-wise or annually: the court reasons that Section 201(3) links commencement to the financial year in which the relevant TDS statement is filed and Rule 31A requires quarterly filings, so each quarterly filing triggers its own two-year limitation. Applying strict construction of fiscal limitation provisions, orders relating to the first three quarters are time-barred and set aside, while the order for the fourth quarter falls within limitation; outcome favourable to the assessee. en-us Thu, 05 Mar 2026 00:00:00 +0530 Sat, 07 Mar 2026 08:39:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787528 Whether the limitation under Section 201(3) is computed quarter-wise or annually: the court reasons that Section 201(3) links commencement to the financial year in which the relevant TDS statement is filed and Rule 31A requires quarterly filings, so each quarterly filing triggers its own two-year limitation. Applying strict construction of fiscal limitation provisions, orders relating to the first three quarters are time-barred and set aside, while the order for the fourth quarter falls within limitation; outcome favourable to the assessee. Case-Laws Income Tax Thu, 05 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787528