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2023 (7) TMI 279 - AT - Income TaxLevy of fees u/s 234E - failure to file return of TDS u/s 201A(1) r.w.s. 194IA - Scope of amended with effect from 01.06.2015 - HELD THAT:- The issue in the present appeal was dealt with in the case of Rajesh Kourani [2017 (7) TMI 458 - GUJARAT HIGH COURT] who after distinguishing the decision in 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 date of 01.06.2015 for the amendment brought in section 200A, no reasons to interfere with the finding CIT(A) who had confirmed the fee imposed by the learned AO u/s 234E of the Act. Accordingly, appeal of the assessee is dismissed.
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