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Tax Case on Payments to Non-Residents: Section 201 Order Limit is One Year; Section 201(3) Not Applicable.

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....Assessee in default - proceedings u/s. 201(1) and 201(1A) - payment to non resident u/s 195 - limitation to pass order u/s. 201 shall be one year from the end of financial year in which proceedings u/s. 201 were initiated - Section 201(3) does not apply as it relates only to the payments made without TDS to person resident in India....