TaxTMI 
TaxTMI 
2012 (5) TMI 88
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....mitation when there is no such provisions of time limitation for passing order u/s 201(1) & 201(IA) in the Income Tax Act, 1961." 2. Briefly stated facts are that assessee (respondent herein) is engaged in running a hydro-electric power project within the State of Himachal Pradesh. Certain lands were acquired by the Government for the purposes of setting up of the said project. With respect to the year 1997-98 certain amounts towards the enhanced amount of compensation and interest payable to the land owners were deposited by the assessee pursuant to directions issued by the High Court of Himachal Pradesh. 3. However, assessee did not deduct tax at source before making payment of interest to the land owners. As such, notices under Section....
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....salary to its employees who were posted in India in two ways. Part of the salary was paid in India and part of the salary which was termed as "global salary" was paid in the home country of the employees. The assessee deducted tax at source in respect of the salary paid in India but did not deduct tax at source in respect of the salary paid in the home country of the employees. It was found that this was not proper and in fact, the assessee was bound to deduct tax even on the salary paid in the native country of the employees. The assessee in fact did not dispute its liability in this regard. The question which arose before the Delhi High Court was whether any period of limitation is applicable to proceedings under Section 201 and 201(1A) o....
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....sideration for the purpose of this case. Even though the period of three years would be a reasonable period as prescribed by section 153 of the Act for completion of proceedings, we have been told that the Income-tax Appellate Tribunal has, in a series of decisions, some of which have been mentioned in the order which is under challenge before us, taken the view that four years would be a reasonable period of time for initiating action, in a case where no limitation is prescribed. The rationale for this seems to be quite clear-if there is a time limit for completing the assessment, then the time limit for initiating the proceedings must be the same, if not less. Nevertheless, the Tribunal has given a greater period for commencement or ini....