2024 (4) TMI 1367

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....T AND HON'BLE MR JUSTICE C.M. POONACHA For the Appellants: (By Sri. Y.V. Raviraj., Advocate). For the Respondent: (By Sri Manish Kanth, Advocate for Ms. Tanmayee Rajkumar., Advocate). JUDGMENT 1. Heard Sri Y.V. Ravi Raj, learned Counsel appearing for the appellants and Sri Manish Kanth, learned Counsel for Ms. Tanmayee Rajkumar, learned counsel for the respondent. 2. This appeal....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... is justified in ignoring the memorandum to Finance Bill 2009 clearly states that no time limits are prescribed in case where deductee is a non-resident? 4. Whether Tribunal's order can be said as perverse in nature in holding that no proceedings under section 201 of the Act were pending before the Assessing Officer as on 01.04.2010 and by the time the proceedings under section 201 of....