Any attempt to reopen and revive the proceedings-after the limited is legally untenable
The Hon’ble Delhi High Court has allowed the writ petition filed on behalf of Swiftrans International Pvt. Ltd. in W.P.(C) 3759/2025, setting aside the TDS demand raised by the Income Tax Department under Sections 201(1), 201(1A), and 260(1A) of the Income Tax Act.
The Court held that the department’s order dated 20.02.2025 was issued beyond the legally permitted timeframe under Section 201(3), and that the previous order dated 21.03.2024 (passed in the first round of proceedings) did not contain any specific finding or direction that could justify extending the limitation period under Section 153(6)(i).
In simple terms: the attempt to reopen and revive the proceedings-after the deadline had already passed on 31.03.2023-was held to be legally untenable.
The copy of the order is as under:
