Generate professional replies to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
Step 1 – Issue Identification & Review
The AI analyses your query, notice, order, or uploaded documents and identifies the key issues involved.
• Review the issues identified by the AI • Add, edit, remove, or refine issues as required
Step 2 – Draft Generation
Once you approve the issues, the AI performs issue-wise legal research and prepares a structured draft response.
• Relevant statutory provisions • Judicial precedents and Supreme Court, High Court and other citations • Issue-wise legal analysis • Practical arguments and supporting content • Professionally structured draft ready for further review.
Late filing fees under Sec. 234E nullified by ITAT Mumbai for AY 2014-16 due to pre-01.06.2015 invalidity Late filing fees under Sec. 234E for A.Y. 2014-15 were set aside by the ITAT, Mumbai, as pre-01.06.2015 fees were deemed invalid. For A.Y. 2015-16, the ...
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Late filing fees under Sec. 234E nullified by ITAT Mumbai for AY 2014-16 due to pre-01.06.2015 invalidity
Late filing fees under Sec. 234E for A.Y. 2014-15 were set aside by the ITAT, Mumbai, as pre-01.06.2015 fees were deemed invalid. For A.Y. 2015-16, the ITAT deleted the late filing fees based on the precedent set in the previous year's judgment. The appeal for A.Y. 2016-17 was dismissed as the late filing fees were not contested post-01.06.2015. The judgments highlighted the inconsistency of levying fees under Sec. 234E before 01.06.2015, in line with legal precedents and statutory provisions.
Issues: Late filing fees under Sec. 234E for A.Y. 2014-15, A.Y. 2015-16, and A.Y. 2016-17.
A.Y. 2014-15: The assessee delayed filing the TDS statement for A.Y. 2014-15, leading to the imposition of late filing fees and interest. The CIT(A) upheld the fees under Sec. 234E, citing statutory provisions. The assessee contended that no fee could be levied pre-01.06.2015. The AR relied on legal precedents to support this argument. The ITAT, Mumbai, referred to judgments from Karnataka and Chandigarh, agreeing that fees under Sec. 234E before 01.06.2015 were invalid. Consequently, the late filing fee was set aside, while interest on late payment was upheld.
A.Y. 2015-16: Similar to A.Y. 2014-15, the assessee faced late filing fees for A.Y. 2015-16. The CIT(A) upheld the fees, rejecting the assessee's argument against pre-01.06.2015 fees. Referring to the previous year's judgment, the ITAT deleted the late filing fees for A.Y. 2015-16.
A.Y. 2016-17: The appeal for A.Y. 2016-17 challenged late filing fees. The AR did not contest the fees for this year, as they were post-01.06.2015. Consequently, the appeal for A.Y. 2016-17 was dismissed as not pressed.
In conclusion, the ITAT, Mumbai, allowed the appeal for A.Y. 2014-15, set aside the late filing fees for A.Y. 2015-16, and dismissed the appeal for A.Y. 2016-17 due to no contest on late filing fees. The judgments emphasized the invalidity of fees under Sec. 234E before 01.06.2015, aligning with legal precedents and statutory provisions.
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