2025 (10) TMI 657

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....AVEEN CHANDRA, ACCOUNTANT MEMBER:- This appeal by the assessee is preferred against the order of the JCIT, Ahmedabad dated 21.02.2025 for A.Y 2015-16. 2. The solitary grievance of the assessee in this appeal is that the ld. CIT(A) has upheld the disallowance u/s 201(1) of the Income-tax Act, 1961 [the Act, for short] for non-deduction of TDS on External Development Charges paid to DTCP. 3....

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....a District Co-op Milk Producers Union Ltd case. This decision meant that any proceedings under Section 201 that were initiated more than four years after the default occurred were considered time-barred and could be set aside. The hon'ble Delhi High Court held that date of knowledge is not relevant for the purpose of exercising jurisdiction so far as provisions of the Act are concerned. 5. In t....