Court Rules Pre-2014 TDS Limitation Period Applies; Amendment Can't Retroactively Extend Time or Affect Vested Rights.

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....Default u/s 201(1) and 201(1A) - period of limitation - TDS u/s 194H - The limitation of 2 years as prescribed in Section 201(1A)(3) of the Act as it existed prior to its substitution by Act No.2/2014 applies to the facts of the case. The limitation to pass an order u/s 201(1A) of the Act expired prior to Finance Act No.2/2014, which came into force with effect from 01.10.2014. Thus, a right accrued to the assessee and the subsequent amendment therefore, could not have revived the period of limitation and take away the vested right accrued to the assessee. - HC....