Section 200A processing could not levy late filing fee under section 234E for pre-amendment TDS statements.

For TDS statements filed for periods before the 1 June 2015 amendment to section 200A, the processing provision permitted only limited adjustments, including arithmetical errors, apparent incorrect claims, and interest as then authorised. The power to compute and levy late filing fee under section 234E through an intimation under section 200A arose only after that amendment. As the impugned intimation was issued before the amendment took effect, there was no enabling provision to demand the fee through processing. The late filing fee levied under section 234E was therefore unsustainable and was deleted.

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Issues: Whether late filing fee levied under section 234E could be adjusted and demanded through intimation under section 200A for a TDS statement filed for a period prior to the amendment to section 200A.

Analysis: The Tribunal followed its earlier view that, for the relevant period, section 200A permitted only limited adjustments while processing TDS statements, namely arithmetical errors, incorrect claims apparent from the statement, and interest as then provided by law. The power to compute and levy fee under section 234E through section 200A came only with the amendment effective from 1 June 2015. Since the impugned intimation was issued before that date, no enabling provision existed to raise the demand through processing under section 200A.

Conclusion: The levy of late filing fee under section 234E through the impugned intimation was unsustainable and was deleted in favour of the assessee.

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