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INCOME TAX APPELLATE TRIBUNAL (CHENNAI BENCH)
Manu Kumar Giri, Judicial Member, S. R. Raghunatha, Accountant Member
Paul System Technologies Private Limited – Appellant
Versus
Income Tax Officer – Respondent
| Table of Content |
|---|
| 1. belated tds returns processed with late fee levy pre-amendment. (Para 2 , 3 , 4) |
| 2. assessee contests delay and invalid pre-2015 levy. (Para 6 , 7 , 8 , 9) |
| 3. delay condoned for bona fide reasons. (Para 10 , 11) |
| 4. no s.200a power for s.234e levy before 01.06.2015. (Para 12 , 13 , 14 , 15) |
| 5. pre-2015 levies deleted; post-amendment upheld. (Para 16 , 17) |
आदेश/ORDER
PER BENCH:
These bunch of 9 (Nine) appeals of the assessee are filed against the order of the learned Commissioner of Income Tax (Appeals), ADDL/JCIT (A)-4, (NFAC), Delhi, (in short “ld.CIT(A)”) for the assessment year (A.Y.) 2014-15 ( 26Q – Q1, Q2, Q4 and 24Q – Q4), 2015-16 ( 26Q – Q1, Q2, Q3 and Q4) and 2016-17 (26Q – Q1) vide orders in respect of the intimation u/s.200A of the Act passed by the TDS CPC as detailed below :
2. The solitary issue raised by the assessee in all the above appeals is that the levy of late fees u/s.234E of the Act in relation to the quarterly TDS returns for the A.Y.2014-15, 2015-16 & the first quarter of A.Y. 2016-17 is unlawful as the enabling provision u/s.200A of the Act has been introduced only from 01.06.2015.
3. Brief facts of the case emanating from the records are that the
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