TMI Blog2021 (3) TMI 1417X X X X Extracts X X X X X X X X Extracts X X X X ..... f 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 val ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Heard both the parties. Case files perused. 2. At the outset, the learned authorized representative submitted that the CIT(A) erred in confirming the levy of late filing fee u/s. 234E r.w.s. 221(1) of the Act. He contended that prior to the amendment u/s. 200A of the Act w.e.f. 1.6.2015, levy of fee u/s. 234E during processing of the TDS statement was not tenable. He relied on the following ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ee u/s. 234E of the Act, hence, the intimation issued by the Assessing Officer 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. 4. Th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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