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TMI Blog2023 (7) TMI 279X X X X Extracts X X X X X X X X Extracts X X X X ..... the case of Fatheraj Singhvi Vs. Union of India [ 2016 (9) TMI 964 - KARNATAKA HIGH COURT] observed that section 234E was introduced to make TDS provisions stringent which is a charging section and section 200A on the other hand is a machinery provisions for making prima facie adjustment. Late filing fee imposed by AO in respect of delayed filing of TDS statement which is after the effective ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the Income-tax Act, 1961 (hereinafter referred to as the Act ), dated 13.04.2019 passed by ACIT, CPC-TDS, Ghaziabad for financial year 2018-19 relevant to assessment year 2019- 20. 2. The solitary ground taken by the assessee is in respect of levy of fees of Rs. 1,59,200 under Section 234E of the Act for failure to file return of TDS under Section 201A(1) read with section 194IA. 3. Brie ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nobody has represented the assessee and wherever there was a representation, it was for the purpose of seeking an adjournment. Further, we note that the issue involved in the present appeal is no longer res integra as the period for which the fee has been imposed is after the date of 01.06.2015 where from an amendment was brought in under Section 200A of the Act. With the ab le assistance of learn ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... default in furnishing of TDS statement. Provisions of section 234E came into force w.e.f. 01.07.2012. Further, provisions of section 200A(1)(c), (d) and (f) came into force w.e.f. 01.06.2015 whereby it was provided that the fee under Section 234E of the Act can be computed at the time of processing of return and intimation can be issued specifying the same, payable by the deductor as fee under Sec ..... X X X X Extracts X X X X X X X X Extracts X X X X
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