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7 years limit to take action against assessee-in-default not applicable retrospectively to time barred orders

August 9, 2019[2019] 108 126 (Mumbai)/[2019] 72 ITR(T) 132 (Mumbai)/[2019] 178 ITD 39 (Mumbai)

INCOME TAX : Increased limitation of seven years under section 201(3) as amended by Finance (No. 2) Act, 2014 with effect from 1-4-2014, shall not apply retrospectively to orders which had already become time barred under old time limitation of two years as set out by unamended section 201(3)(i) and, thus, no order under section 201(1)/201(1A) deeming tax deductor to be assessee in default can be passed if limitation has already expired as on 1-4-2014
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