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Levy of fee u/s 234E - TDS return default - Even in absence of such provision as noted it was always open for the Revenue to charge the fee in terms of section 234E of the Act. By amendment this adjustment was brought within the fold of section 200A of the Act. Upon introduction of the recasted clause (c) this situation also would be obviated. Even prior to 01.06.2015 it was always open for the Revenue to calculate fee in terms of section 234E - HC

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