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2023 (4) TMI 20 - AT - Income TaxLevy of late filing fee u/s 234E - processing of statements filed by the assessee u/s. 200A - levy of fee u/s. 234E(1) in respect of statements delivered u/s. 200(3)/206C(3) after 01/7/2012 but before 01/6/2015 - HELD THAT:- For statements furnished after 31/5/2015, any delay relatable to the period after 30/6/2012, could be taken cognizance of. The statement/s u/s. 200(3) having been filed in the instant case/s after 01/06/2015, its processing u/s. 200A(1)(c), determining the amount payable u/s. 234E, admits of no two views (s.200A(1)(d/e/f, as they stand w.e.f. 01/6/2015). The delay taken cognizance of, and with reference to which fee is levied, is in the instant cases covered by the period falling after 31/5/2015. The controversy arising due to the difference in the view of the Hon’ble Courts does not attend the instant case, so that the levy in the instant case admits of no two views. The same cannot therefore be regarded as debatable from any stand point, even as we have clarified our view even in case of periods falling after 30/6/2012. We, accordingly, uphold the levy.
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