Amendment to Income Tax Act Sec. 201(1) in 2014 doesn't revive expired cases; notices after March 31, 2012, are invalid.

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....TDS liability - period of limitation - The limitation for initiating action under section 201(1) of the Act, therefore, expired on 31st March, 2012 whereas the amendment in section 201 of the Act as amended by Finance Act No.2 of 2014 came into force with effect from 28th May, 2012 - the notices are clearly barred by limitation - HC....