M/S. SARTORIUS STEDIM INDIA PRIVATE LIMITED,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, TDS CIRCLE- 3(1), BENGALURU

In the result appeal is filed by assessee stands allowed

Bench: Shri. B. R. Baskaran & Smt. Beena Pillaiassessment Year : 2010-11

194J as well as section 195) and the provisions of respective tax treaty. Accordingly, provisions of section 201 are not attracted; c) Passing order u/s 20](1) & (IA) after almost seven years appreciating that the same is barred by limitation. 3. The learned CIT(A) has erred in not appreciating that in the absence of limitation period under section