Extension of Limitation Period u/s 201(1)/1A Doesn't Apply to AY 2011-12 Due to Pre-Amendment Expiry.

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....Default u/s 201(1)/1A - period of limitation - limitation period was substituted from four years to six years for passing orders where TDS Statement had not been filed. - As specifically stated that the said amendment will take effect from 1/10/2014. As observed hereinabove, in the present cases, limitations provided for passing order under section 201(1) of the Act for A.Y. 2011-12 had already been expired on 31/3/2014 i.e. prior to section 201(3) came to be amended by Finance Act No.2 of 2014. - AT....