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“Section 201(3)”

Section References (mined)Section 201Section 201(3)157 judgments

SHIV SAI INFRASTRUCTURE PVT LTD,DELHI vs. ITO WARD-77(2), DELHI

In the result, the appeal of the assessee is allowed

ITA 2703/DEL/2025[2014-15]Status: DisposedITAT Delhi30 Dec 2025AY 2014-15

Bench: Shri C. N. Prasad & Shri M. Balaganeshshiv Sai Infrastructure Pvt. Ltd, Vs. Ito (Tds), E-42, Greater Kailash, Part-Ii, Ward-77(2), New Delhi Delhi (Appellant) (Respondent) Pan: Dels29867F Assessee By : Shri Raj Kumar, Ca Shri Suraj Gupta, Adv Revenue By: Shri Rajesh Kumar Dhanesta, Sr Dr Date Of Hearing 26/11/2025 Date Of Pronouncement 30/12/2025

For Appellant: Shri Raj Kumar, CAFor Respondent: Shri Rajesh Kumar Dhanesta, Sr DR
Section 133ASection 194CSection 194C(1)Section 201Section 201(1)

charges payable to HUDA in view of the aforesaid facts and provisions of the Act. Further as per the provisions of section 201(3) of the Act, no order under section 201 of the Act could be passed after the expiry of 7 years from the end of the financial

STATE BANK OF INDIA,SMECC, ZONAL OFFICE,KANPUR vs. ACIT9TDS), KANPUR

In the result, both appeals of the assessee are allowed for statistical purposes

ITA 636/LKW/2024[1018-19]Status: DisposedITAT Lucknow29 Jul 2025AY 1018-19

Bench: Shri Kul Bharat & Shri Anadee Nath Misshraassessment Year: 2016-17 State Bank Of India V. Dcit (Tds) The Mall Road, Kanpur Nagar- 7/119, Radiance Town, 208001. Swaroop Nagar, Kanpur Nagar-208002. Pan:Knps02318B (Appellant) (Respondent) Assessment Year: 2018-19 State Bank Of India V. Addl. Cit (Tds) The Mall Road, Kanpur Nagar- 7/119, Radiance Town, 208001. Swaroop Nagar, Kanpur Nagar-208002. Pan: Knps02318B (Appellant) (Respondent) Appellant By: Shri R. K. Agarwal, Adv Respondent By: Shri Amit Kumar, Cit(Dr) Date Of Hearing: 21 07 2025 Date Of Pronouncement: 29 07 2025 O R D E R

For Appellant: Shri R. K. Agarwal, AdvFor Respondent: Shri Amit Kumar, CIT(DR)
Section 10(5)Section 201Section 201(1)Section 201(3)Section 271C

barred by limitation and hence, void — ab - initio. (2) That Learned Additional CIT (A), NFAC, has erred in holding that the provisions of section 201(3) of the Income Tax Act 1961, as amended by Finance Act, 2014 are retrospective in nature and applies to the captioned assessment year. (3

STATE BANK OF INDIA, ZONAL OFFICE,KANPUR vs. DY. CIT (TDS), KANPUR

In the result, both appeals of the assessee are allowed for statistical purposes

ITA 635/LKW/2024[2016-17]Status: DisposedITAT Lucknow29 Jul 2025AY 2016-17

Bench: Shri Kul Bharat & Shri Anadee Nath Misshraassessment Year: 2016-17 State Bank Of India V. Dcit (Tds) The Mall Road, Kanpur Nagar- 7/119, Radiance Town, 208001. Swaroop Nagar, Kanpur Nagar-208002. Pan:Knps02318B (Appellant) (Respondent) Assessment Year: 2018-19 State Bank Of India V. Addl. Cit (Tds) The Mall Road, Kanpur Nagar- 7/119, Radiance Town, 208001. Swaroop Nagar, Kanpur Nagar-208002. Pan: Knps02318B (Appellant) (Respondent) Appellant By: Shri R. K. Agarwal, Adv Respondent By: Shri Amit Kumar, Cit(Dr) Date Of Hearing: 21 07 2025 Date Of Pronouncement: 29 07 2025 O R D E R

For Appellant: Shri R. K. Agarwal, AdvFor Respondent: Shri Amit Kumar, CIT(DR)
Section 10(5)Section 201Section 201(1)Section 201(3)Section 271C

barred by limitation and hence, void — ab - initio. (2) That Learned Additional CIT (A), NFAC, has erred in holding that the provisions of section 201(3) of the Income Tax Act 1961, as amended by Finance Act, 2014 are retrospective in nature and applies to the captioned assessment year. (3

THE DISTRICT MINING OFFICER,BAREILLY vs. INCOME TAX OFFICER (TDS), BAREILLY

ITA 246/LKW/2018[2008-09]Status: DisposedITAT Lucknow30 Jun 2025AY 2008-09

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Revenue byFor Respondent: Date of hearing
Section 133ASection 206CSection 250

years 2009-10 to 2012-13, that even though the limitation had not been prescribed within section 201, since the provisions of amended section 201(3) as amended w.e.f. 1.10.2014 were not retrospective, the orders passed by the ld. AO in those cases were barred by limitation

ACIT, DELHI vs. M/S. VODAFONE ESSAR MOBILE SERVICES LTD., NEW DELHI

In the result, the appeal of the Revenue is allowed for\nstatistical purposes

ITA 983/DEL/2015[2006-07 (F.Y.- 2005-06)]Status: DisposedITAT Mumbai22 May 2025
Section 194Section 201Section 201(1)

notice issued by the Revenue seeking to initiate\nthe proceedings against the assessee to declare them to be the assessee\nin default under section 201(3) of the Act, as such the determination the\nTDS liability done by the AO u/s 201/201(1)(A) of the Act does not\nsurvive

THE REGIONAL MANAGER STATE BANK OF INDIA ,FARRUKHABAD vs. ITO (TDS) , ALIGARH

ITA 199/AGR/2022[2014-15]Status: DisposedITAT Agra19 May 2025AY 2014-15

Bench: : Shri Sunil Kumar Singh & Shri Brajesh Kumar Singh

IN THE INCOME TAX APPELLATE TRIBUNAL, AGRA BENCH, AGRA BEFORE : SHRI SUNIL KUMAR SINGH, JUDICIAL MEMBER AND SHRI BRAJESH KUMAR

STATE BANK OF INDIA, ZONAL OFFICE(15875),PATHANKOT vs. INCOME TAX OFFICER (TDS-I), CHANDIGARH

The appeal is dismissed

ITA 653/CHANDI/2024[2016-17]Status: DisposedITAT Chandigarh25 Mar 2025AY 2016-17

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

submitted by the Ld. AR that the action carried out by the officer was beyond the period of time as provided under section 201(3) of the Act and 5 therefore all the actions taken by the AO for the A.Y. 2013-14 and 2014-15, were beyond the period ... deductor, the same was thereafter extended vide the Finance Act, 2012 from 4 years as was earlier provided in clause (ii) to section 201(3) of the Act to a period of 6 years with retrospective effect from 1-4-2010, i.e., from AY 2010-11 onwards. However, the time

STATE BANK OF INDIA,AMRITSAR vs. JOINT COMMISSIONER OF INDIA (IN-SITU), LUDHIANA

The appeal is dismissed

ITA 643/CHANDI/2024[2016-17]Status: DisposedITAT Chandigarh25 Mar 2025AY 2016-17

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

submitted by the Ld. AR that the action carried out by the officer was beyond the period of time as provided under section 201(3) of the Act and 5 therefore all the actions taken by the AO for the A.Y. 2013-14 and 2014-15, were beyond the period ... deductor, the same was thereafter extended vide the Finance Act, 2012 from 4 years as was earlier provided in clause (ii) to section 201(3) of the Act to a period of 6 years with retrospective effect from 1-4-2010, i.e., from AY 2010-11 onwards. However, the time

STATE BANK OF INDIA, SAMB BRANCH,CHANDIGARH vs. INCOME TAX OFFICER (TDS-1), CHANDIGARH

The appeal is dismissed

ITA 626/CHANDI/2024[2016-17]Status: DisposedITAT Chandigarh25 Mar 2025AY 2016-17

Bench: BEFORE: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

submitted by the Ld. AR that the action carried out by the officer was beyond the period of time as provided under section 201(3) of the Act and 5 therefore all the actions taken by the AO for the A.Y. 2013-14 and 2014-15, were beyond the period ... deductor, the same was thereafter extended vide the Finance Act, 2012 from 4 years as was earlier provided in clause (ii) to section 201(3) of the Act to a period of 6 years with retrospective effect from 1-4-2010, i.e., from AY 2010-11 onwards. However, the time

STATE BANK OF INDIA,CHANDIGARH vs. INCOME TAX OFFICER (TDS-1),, CHANDIGARH

The appeal is dismissed

ITA 623/CHANDI/2024[2016-17]Status: DisposedITAT Chandigarh25 Mar 2025AY 2016-17

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

submitted by the Ld. AR that the action carried out by the officer was beyond the period of time as provided under section 201(3) of the Act and 5 therefore all the actions taken by the AO for the A.Y. 2013-14 and 2014-15, were beyond the period ... deductor, the same was thereafter extended vide the Finance Act, 2012 from 4 years as was earlier provided in clause (ii) to section 201(3) of the Act to a period of 6 years with retrospective effect from 1-4-2010, i.e., from AY 2010-11 onwards. However, the time

STATE BANK OF INDIA,CHANDIGARH vs. DCIT/ACIT (TDS), CHANDIGARH

The appeal is dismissed

ITA 622/CHANDI/2024[2016-17]Status: DisposedITAT Chandigarh25 Mar 2025AY 2016-17

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

submitted by the Ld. AR that the action carried out by the officer was beyond the period of time as provided under section 201(3) of the Act and 5 therefore all the actions taken by the AO for the A.Y. 2013-14 and 2014-15, were beyond the period ... deductor, the same was thereafter extended vide the Finance Act, 2012 from 4 years as was earlier provided in clause (ii) to section 201(3) of the Act to a period of 6 years with retrospective effect from 1-4-2010, i.e., from AY 2010-11 onwards. However, the time

STATE BANK OF INDIA,PANCHKULA vs. DCIT/ACIT-TDS, CHANDIGARH

The appeal is dismissed

ITA 493/CHANDI/2024[2016-17]Status: DisposedITAT Chandigarh25 Mar 2025AY 2016-17

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

submitted by the Ld. AR that the action carried out by the officer was beyond the period of time as provided under section 201(3) of the Act and 5 therefore all the actions taken by the AO for the A.Y. 2013-14 and 2014-15, were beyond the period ... deductor, the same was thereafter extended vide the Finance Act, 2012 from 4 years as was earlier provided in clause (ii) to section 201(3) of the Act to a period of 6 years with retrospective effect from 1-4-2010, i.e., from AY 2010-11 onwards. However, the time

STATE BANK OF INDIA,CHANDIGARH vs. DCIT/ACIT-TDS, CHANDIGARH

The appeal is dismissed

ITA 173/CHANDI/2024[2016-17]Status: DisposedITAT Chandigarh25 Mar 2025AY 2016-17

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

submitted by the Ld. AR that the action carried out by the officer was beyond the period of time as provided under section 201(3) of the Act and 5 therefore all the actions taken by the AO for the A.Y. 2013-14 and 2014-15, were beyond the period ... deductor, the same was thereafter extended vide the Finance Act, 2012 from 4 years as was earlier provided in clause (ii) to section 201(3) of the Act to a period of 6 years with retrospective effect from 1-4-2010, i.e., from AY 2010-11 onwards. However, the time

STATE BANK OF INDIA,CHANDIGARH vs. ITO (TDS-I), CHANDIGARH

The appeal is dismissed

ITA 376/CHANDI/2023[2014-15]Status: DisposedITAT Chandigarh25 Mar 2025AY 2014-15

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

submitted by the Ld. AR that the action carried out by the officer was beyond the period of time as provided under section 201(3) of the Act and 5 therefore all the actions taken by the AO for the A.Y. 2013-14 and 2014-15, were beyond the period ... deductor, the same was thereafter extended vide the Finance Act, 2012 from 4 years as was earlier provided in clause (ii) to section 201(3) of the Act to a period of 6 years with retrospective effect from 1-4-2010, i.e., from AY 2010-11 onwards. However, the time

STATE BANK OF INDIA,CHANDIGARH vs. ITO (TDS-I), CHANDIGARH

The appeal is dismissed

ITA 375/CHANDI/2023[2013-14]Status: DisposedITAT Chandigarh25 Mar 2025AY 2013-14

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

submitted by the Ld. AR that the action carried out by the officer was beyond the period of time as provided under section 201(3) of the Act and 5 therefore all the actions taken by the AO for the A.Y. 2013-14 and 2014-15, were beyond the period ... deductor, the same was thereafter extended vide the Finance Act, 2012 from 4 years as was earlier provided in clause (ii) to section 201(3) of the Act to a period of 6 years with retrospective effect from 1-4-2010, i.e., from AY 2010-11 onwards. However, the time

ASSISTANT COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION vs. ALLSCRIPTS (INDIA) PRIVATE LIMITED , VADODARA.

In the result, the appeal of the Revenue is dismissed

ITA 1373/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad07 Feb 2025AY 2014-15

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year : 2014-15 Asstt.Cit (International Allscripts (India) Pvt. Ltd. Taxation),Vadodara. Vs 10Th & 11Th Floor, Atlantis Heights Dr. Vikram Sarabhai Road Vadodara. Pan : Aaccm 2641 J (Applicant) (Responent) : Assessee By Shri Rajpat Soni, Ar : Shri Amit Pratap Singh, Sr.Dr. Revenue By सुनवाई क" तारीख/Date Of Hearing : 08/01/2025 घोषणा क" तारीख /Date Of Pronouncement: 07/02/2025 आदेश/O R D E R आदेश आदेश आदेश

Section 195Section 201Section 201(1)Section 201(3)Section 250

erred in law and on facts by ignoring the CBDT's memorandum, explaining the provisions of the amendment by which Section 201(3) was substituted with effect from 01,04.2010 which explicitly says that bar of limitation u/s, 201(3) does not apply where the deductee is a non-residents ... resident deductee, which is neither available as per the provisions of the Act nor by the CBDTs memorandum, explaining the provisions of Section 201 (3) of the IT Act? (v) Whether the Hon'ble CIT(A) has erred in law and on facts by ignoring the provisions of Section 201

M/S. ALLSEC TECHNOLOGIES LIMITED,CHENNAI vs. DCIT,INTL TAX -1(1, CHENNAI, CHENNAI

In the result, the appeal stand dismissed

ITA 1512/CHNY/2023[2015-16]Status: DisposedITAT Chennai03 Dec 2024AY 2015-16

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.1512/Chny/2023 (िनधा)रणवष) / Assessment Year: 2015-16) M/S. Allsec Technologies Limited Dcit बनाम/ 46C, Velachery Main Road, Velacherry, International Taxation-1(1) Vs. Chennai-600 042. Chennai. "थायीलेखासं./जीआइआरसं./Pan/Gir No.Aacca-5106-G (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Vikram Vijayaraghavan (Advocate)-Ld.Ar " थ"कीओरसे/ Respondent By : Ms. Kavitha (Addl.Cit) - Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 20-11-2024 घोषणाकीतारीख /Date Of Pronouncement : 03-12-2024 आदेश / O R D E R

For Appellant: Shri Vikram Vijayaraghavan (Advocate)-Ld.ARFor Respondent: Ms. Kavitha (Addl.CIT) - Ld. DR
Section 143(3)Section 201Section 201(1)Section 201(3)Section 40Section 9(1)(i)

आयकर अपीलीय अिधकरण “डी” "ायपीठ चे"ई म"। IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, CHENNAI माननीय "ी मनोज कुमार

DCIT, LAXMINAGAR vs. TURNER GENERAL ENTERTAINMENT NETWORKS INDIA PRIVATE LIMITED, MAHIPALPUR DELHI

In the result, assessee's appeal is partly

ITA 473/DEL/2024[2011-12]Status: DisposedITAT Delhi14 Nov 2024AY 2011-12

Bench: Sh. M. Balaganesh & Sh. Sudhir Kumarassessment Year: 2011-12 Dcit Vs Turner General Laxmi Nagar Entertainment Net Works New Delhi India Limited Mahipalpur Delhi Tan No. Deln08096E (Appellant) (Respondent)

Section 201Section 201(1)Section 201(3)Section 271CSection 3

limit. 9. The Ld AR has submitted that the order passed by the AO was time barred by limitation. He has submitted that section 201(3) of the Act provides the time limit within which an order u/s 201(1) of the Act can be made. He has also submitted ... reads as under :- Section 201 of the Act provides for consequences of failure to deduct or pay taxes at source. Section 201(3) of the Act provides for time limit within which an order under Section 201(1) of the act can be made. Section 201(3) and Section 201

INDOWORTH INDIA LIMITED,NAGPUR vs. ACIT(TDS), CIRCLE 51(1), NAGPUR

In the result, appeal filed by the assessee for A

ITA 4/NAG/2024[2013-14]Status: DisposedITAT Nagpur23 Sept 2024AY 2013-14

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri R.K. GaneriwalFor Respondent: Shri Abhay Y. Marathe
Section 201Section 201(1)Section 201(3)

illegal, incorrect, bad in law and without natural justice. 2. The order passed by AO is TDS demand is time barred as per section 201(3) the Financial Act, 2012. 3. The non–deduction TDS and interest thereon u/s 201(1) and 201(1A) on share application money of Rs.55 ... assessee as well as the learned Departmental Representative, we find that since the issue relating to the provisions of limitation under section 201(3) of the Income Tax Act, 1961 ("the Act") goes to the root of the matter and does not require investigation of fresh facts, therefore, we admit

M/S INDOWORTH INDIA LIMITED,NAGPUR vs. ACIT(TDS), CIRCLE 51(1) , NAGPUR

In the result, appeal filed by the assessee for A

ITA 3/NAG/2024[2012-13]Status: DisposedITAT Nagpur23 Sept 2024AY 2012-13

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri R.K. GaneriwalFor Respondent: Shri Abhay Y. Marathe
Section 201Section 201(1)Section 201(3)

illegal, incorrect, bad in law and without natural justice. 2. The order passed by AO is TDS demand is time barred as per section 201(3) the Financial Act, 2012. 3. The non–deduction TDS and interest thereon u/s 201(1) and 201(1A) on share application money of Rs.55 ... assessee as well as the learned Departmental Representative, we find that since the issue relating to the provisions of limitation under section 201(3) of the Income Tax Act, 1961 ("the Act") goes to the root of the matter and does not require investigation of fresh facts, therefore, we admit

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Section 201(3) — 157 judgments | BharatTax | BharatTax