Reasonable Timeframe Required for Orders u/s 201(1) of Income Tax Act for Non-Deduction of Tax at Source.

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....Demand u/s 201(1) - assessee in default - Period of limitation - the limitation prescribed for passing orders under Section 201(1) of the Act deeming a person to be an “assessee in default” for failure to deduct tax at source in respect of payments to residents would constitute reasonable period in the absence of a legislative prescription of limitation for passing orders under Section 201(1) of the Act, deeming a person to be an “assessee in default” for failure to deduct tax at source in respect of payments to non-residents as well. - HC....