2020 (2) TMI 1557

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....CIT O R D E R M. BALAGANESH, J. This appeal of the assessee arise out of the order of the Ld. Commissioner of Income Tax (Appeals)-16, Chennai vide proceedings in ITA No. 03/CIT(A)-16/2010-11, dated 09.08.2018 against the order passed by the DCIT, International Taxation-2(2), Chennai (AO) u/s. 201(1) & 201(1A) of the Income Tax Act, 1961 (hereafter 'the Act') dated 31.03.2017 for the Asse....

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....1) to s. 201(1) could be passed only within 6 years from the end of the financial year in which the payment was made. There is no dispute in the instant case that payment for purchase of software was made by the assessee during the financial year 2009-10 relevant to A.Y 2010-11. Hence, six years from the end of the financial year would expire on 31-03-2016, which would be the last date for framing....