Period of Limitation u/s 201(3) for passing an order treating deductor as assesse in default and charging interest for delayed payment of TDS for Financial year 2007-08 was confined to 31-03-2011 and it was was later albeit increased to seven years from the end of financial year in which TDS was deposited w.e.f. 01-10-2014.
Delhi High Court in case of Oracle India P Ltd. Held that since notice for financial year 2007-08, after 31-03-2011 was time barred even if later on law increased the period of limitation.