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TMI Blog2024 (3) TMI 718X X X X Extracts X X X X X X X X Extracts X X X X ..... Bali, Sr. DR ORDER PER ANUBHAV SHARMA, JM: These appeals have been preferred by the assessee, challenging the respective orders of learned Commissioner of Income-tax (Appeals), wherein the assessee has challenged the impugned orders of CPC(TDS) for the respective quarters for assessment years 2013-14 and 2015-16 respectively, as detailed below: Appeal No. Assessment Year Quarter Form No. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t, which deals with the manner in which the statement of Tax Deducted at Source (TDS) shall be processed, the Authorities have no power to impose the late fee under section 234E of the Act for the assessment years 2012-2013 to 2015- 16, since section 200A(1)(c) of the Act was introduced only with effect from 1-6-2015. Accordingly, any fee under Sec 234E could have been levied only prospectively, f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ate fee under section 234E of the Act while filing and processing the TDS returns under section 200A of the Act, clause (c) to sub-section (1) to section 200A was introduced with effect from 1- 7-2012. Therefore, the aforesaid submission made by the learned counsel for the respondent is rejected by this Court. 17. In view of the above, it is made clear that the respondent had had imposed the lat ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ry School Vs ACIT, ITAT Delhi, [2020] 121 taxmann.com 170 (Delhi - Trib.) 7. In the light of aforesaid, we are of the considered view that the Ld.CIT(A) has fallen in error in sustaining the levy of penalty in ITA No.878/Del/2023. ..... " 4. Ld. DR has defended the order of ld. Tax authorities on the same premises as emphasized, in hearing of the appeals for earlier quarters, but there being ..... X X X X Extracts X X X X X X X X Extracts X X X X
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