Limitation for section 201 proceedings turns on valid show-cause notice; information letters do not start proceedings, and time-bar applies.

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....Proceedings under section 201(1) were held time-barred because earlier TDS communications were only information requests and did not amount to initiation; the first valid show-cause notice was issued in 2010. The Court accepted that the proviso to section 201(3), allowing completion up to 31 March 2011, applied only to already pending proceedings and could not revive a fresh initiation after limitation had expired. As the period for commencing action had run out for the assessment years concerned, no substantial question of law arose and the Revenue's challenge failed. The appeal was dismissed.....