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2022 (9) TMI 1631

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..... section 200A(1) was inserted by the Finance Act 2015 w.e.f. 01-06-2015 providing for the levy of fee u/s.234E of the Act. In that view of the matter, such fee u/s.234E can be levied only for the default committed after 01-06-2015 and not prior to that. Olari Little Flower Kuries Pvt. Ltd. , [ 2022 (2) TMI 1061 - KERALAHIGH COURT] has affirmed the non-imposition of fee for the period prior to 01-06 .....

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..... for the respective quarters belatedly. Based on that, the Assessing Officer (AO) levied late fees u/s.234E of the Income-tax Act, 1961 (hereinafter also called `the Act ). The assessee approached the ld. CIT(A) but without success. Aggrieved thereby, the assessee has come up before the Tribunal. 3. We have heard both the sides and gone through the relevant material on record. The solitary issue ra .....

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..... ition of fee for the period prior to 01-06-2015. Similar view has been taken in Jiji Varghese VS. ITO(TDS) Ors. (2022) 443 ITR 267 (Ker) holding that no fee u/s 234E can be imposed for the periods of the respective A.Ys. prior to June 1, 2015. Thus, it is seen that the issue raised in these appeals is covered in favour of the assessee. Following the precedent, we overturn the impugned orders on th .....

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