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TMI Blog2025 (1) TMI 1183X X X X Extracts X X X X X X X X Extracts X X X X ..... ribunal after considering the judicial pronouncements have been taking a consistent view that the amendment brought in Finance Act, 2015 w.e.f. 01.06.2015 under Section 200A (clause (c)] of the Act is prospective in nature thereby empowering the Revenue authorities to charge fee u/s.234E of the Act only after 01.06.2015. In that view of the matter, Revenue authorities are empowered to impose such late fee u/s.234E only for the default committed after 01.06.2015 and not prior to that. Late fee u/s.234E has been imposed for the delay in furnishing the statements and the returns have been processed u/s.200A of the Act after 01.06.2015 - Penalty u/s.234E is leviable since amendment brought in Finance Act, 2015 w.e.f. 01.06.2015 under Section 2 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d appeal(s) before Ld. CIT(A)/NFAC but failed to get any relief. Now the assessee is in appeal(s) before the Tribunal. 4. Ld. Departmental Representative supported the orders passed by the lower authorities and vehemently argued for confirming the late fee levied u/s.234E of the Act. 5. We have heard both the parties and perused the records placed before us. The solitary issue in this batch of appeals is against the levy of fee u/s.234E of the Act by CPC for delay in filing the TDS quarterly returns and Ld. CIT(A)/NFAC confirming such levy of fee u/s.234E for filing the Quarterly returns after the due date. 6. We observe that the issue of levy of fee u/s.234E is no more res integra by virtue of several decisions rendered by this Tribunal ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the assessee as the returns u/s.200A(c) were processed before 01.06.2015. Sl. No. ITA No(s). Asst. Year Quarter Form Order date 1 ITA Nos.2299/PUN/2024 2013-14 Q4 26Q 20.01.2014 2 ITA No.2300/PUN/2024 2014-15 Q1 26Q 15.03.2014 3 ITA No.2301/PUN/2024 2014-15 Q2 26Q 15.03.2014 4 ITA No.2302/PUU/2024 2014-15 Q3 26Q 15.03.2014 5 ITA No.2303/PUN/2024 2014-15 Q4 26Q 11.10.2014 6 ITA No.2165/PUN/2024 2013-14 Q3 26Q 20.01.2014 7 ITA No.2166/PUN/2024 2013-14 Q2 26Q 20.01.2014 8 ITA No.1322/PUN/2024 2013-14 Q2 26Q 20.01.2014 7. Following the precedent, we overturn the impugned orders on this sole issue and allow the effective grounds of appeal raised by the assessee in all these eight appeals. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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