C.I.T vs M/S.British Airways

The Supreme Court addressed the validity of orders under Sections 201(1) and 201(1A) of the Income Tax Act, 1961, determining that the question of limitation was academic due to a prior judgment in Commissioner of Income Tax vs. Eli Lilly & Co. (India) Pvt. Ltd., which clarified the deductibility of TDS on foreign salary payments. The Court held that even if the Department's position on limitation was correct, the issue of declaring the assessee as in default under Section 192 read with Section 201 could not arise due to the debatable nature of the law at the time. The appeals were disposed of with no order as to costs, leaving the limitation question open.