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

In the result, the appeal of the assessee is partly allowed

condoned the delay in filing the appeal. It held that the issue of limitation for passing orders under section 206C(6A) needed to be decided as a preliminary issue. The Tribunal noted that while previous ITAT decisions applied a 4-year limitation based on Section 201, the jurisdictional High Court's decision indicated that without a prescribed limitation, action should