THE ACIT (INT. TAXA), VADODARA vs. M/S. ALLSCRIPTS (INDIA) PVT.LTD., BARODA
In the result, the appeal of the Revenue is dismissed
ITA 41/AHD/2021[2013-14]Status: DisposedITAT Ahmedabad12 Oct 2022AY 2013-14
Bench: Ms. Suchitra Kamble & Shri Waseem Ahmed
For Appellant: Shri Atul Pandey, Sr. D.RFor Respondent: Shri Nikhil Mutha, A.R
Section 194ISection 195Section 201Section 201(1)Section 201(3)
194I of the Act rendering the judgment obiter dictum in the case of the assessee under consideration. The Ld. D.R. further submitted that the statute defines the period of limitation for passing of order under Section 201 / 201(1A) of the Act with respect to payments to resident assessee whereas the assessee made payments to a non-resident and thus