Prospective application of section 200A amendment bars section 234E fee for TDS statements filed before 01.06.2015.

Amended section 200A clauses inserted by the Finance Act, 2015 with effect from 01.06.2015 were treated as prospective, so fee under section 234E could not be levied while processing TDS statements under section 200A for periods before that date. As the statements related to a pre-01.06.2015 period, the levy was held impermissible and relief was granted to the assessee.

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Issues: Whether fee under section 234E of the Income-tax Act, 1961 could be levied while processing TDS statements under section 200A for periods prior to 01.06.2015.

Analysis: The amended clauses in section 200A, inserted by the Finance Act, 2015 with effect from 01.06.2015, were held to operate prospectively. For the assessment year involved, the TDS statements related to a period prior to that date. Following the earlier coordinate bench view and the conclusion adopted in the relevant precedent, levy of fee under section 234E through processing under section 200A for the pre-01.06.2015 period was treated as impermissible.

Conclusion: Fee under section 234E could not be levied while processing TDS statements under section 200A for the period prior to 01.06.2015. The issue was decided in favour of the assessee.

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