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2021 (3) TMI 1417 - AT - Income TaxLevy of late filing fee u/s. 234E r.w.s. 221(1) - Intimation u/s 200A - As contended that prior to the amendment u/s. 200A w.e.f. 1.6.2015, levy of fee u/s. 234E during processing of the TDS statement was not tenable - HELD THAT:- Issue of amendment in Section 200A(1) of the Act has become very much a debatable issue, we therefore AO while processing the TDS statements, returns in the present set of appeals of the period prior to 1.6.2015, ought not to have charged fee u/s. 234E hence, the intimation issued by the AO u/s. 200A of the Act, in the appeals before us, does not stand, therefore, the demand raised by way of charging fee u/s. 234E of the Act is not valid and the same is deleted for the prior period 1.6.2015, is beyond the scope of adjustment provided u/s. 200A of the Act. The impugned demands are delete therefore. Assessee appeal allowed.
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