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    <title>2026 (11) TMI 468 - ITAT JAIPUR</title>
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    <description>Prospective extension of a statutory limitation period does not revive proceedings already barred before the amendment takes effect. The applicable period for an order treating an assessee as in default was two years from the end of the financial year in which tax deduction statements were filed. The seven-year extension took effect after that period had expired and the right to plead limitation had accrued; the default order was therefore without jurisdiction, and consequential interest could not survive.</description>
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      <description>Prospective extension of a statutory limitation period does not revive proceedings already barred before the amendment takes effect. The applicable period for an order treating an assessee as in default was two years from the end of the financial year in which tax deduction statements were filed. The seven-year extension took effect after that period had expired and the right to plead limitation had accrued; the default order was therefore without jurisdiction, and consequential interest could not survive.</description>
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