Amendment Cannot Extend Expired TDS Order Time Limits; Orders Beyond Limit Are Time-Barred and Quashed.

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....Limit limit to pass order u/s. 201(1)/201(1A) - default for non-deduction of tax at source (TDS) - A subsequent amendment to the provision cannot give a new lease of life to the time limit which has already exhausted. Hence, for the years under consideration, it is only the sub-section (3) as amended by Finance Act, 2012 with retrospective effect from 01-04-2010, which shall prevail. Resultantly, the orders passed by the AO beyond the stipulated time limit are time barred and hence quashed. - AT....