The issues primarily raised in the grounds are:
i) Orders passed u/s. 201 and 201(1A) of the I.T. Act are barred by limitation. ii) No payment was made by the assessee but it was only a book adjustment, therefore, the assessee was not liable to deduct tax on such book adjustment nor assessee had deducted tax at source. According to the assessee there is no TDS payment outstanding for the A.Y. 2007-08 as per the addendum to the auditor’s report dated 11/08/2008. It is to be noted that the assessee has filed rectification application before the Assessing Officer. It is for the assessee to pursue the rectification application filed before the Assessing Officer and prove its case that no TDS payment is outstanding as on 31/03/2007. With these observations, I dismiss the appeal filed by the assessee for AY 2007- 08.