Assessee appeals allowed citing invalid late fees pre-01.06.2015 & recent judicial rulings.

The tribunal allowed the appeals filed by the assessee, emphasizing the invalidity of late fee levies before 01.06.2015 and the favorable impact of recent judicial pronouncements on the case.

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Issues:
- Delay in filing appeals
- Levying of late fees u/s 234E of the I.T. Act
- Applicability of amendments to section 200A of the I.T. Act

Delay in filing appeals:
The appeals were filed by the assessee against four orders of the CIT(A), with a delay of 47 days. The assessee submitted a petition for condonation of delay, providing reasons for the delay. The tribunal found sufficient cause for the delay and proceeded to hear the appeals on merits.

Levying of late fees u/s 234E of the I.T. Act:
The main issue raised in all appeals was whether the CIT(A) erred in confirming the Assessing Officer's orders imposing late fees u/s 234E of the I.T. Act for delayed filing of TDS returns. The CIT(A) upheld the AO's orders based on previous judgments. However, the assessee argued that recent judicial pronouncements favored their case, citing various judgments in support.

Applicability of amendments to section 200A of the I.T. Act:
The tribunal analyzed the amendments to section 200A of the I.T. Act concerning the levy of late fees u/s 234E. It was noted that prior to 01.06.2015, there was no provision for such adjustments. The tribunal referred to the judgment of the Hon'ble Kerala High Court, which held that intimation issued u/s 200A before 01.06.2015 regarding late fees for TDS returns was invalid. The tribunal also discussed the retrospective effect of the amendments and distinguished judgments from other high courts. Ultimately, the tribunal allowed the assessee's claim, ruling in their favor.

In conclusion, the tribunal allowed the appeals filed by the assessee, emphasizing the invalidity of late fee levies before 01.06.2015 and the favorable impact of recent judicial pronouncements on the case.

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