1. Search Case laws by Section / Act / Rule — now available beyond Income Tax. GST and Other Laws Available
2. New: “In Favour Of” filter added in Case Laws.
Try both these filters in Case Laws →
TaxTMI Login
🚀 New: Section-Wise Filter ✕
Just a moment...
1. Search Case laws by Section / Act / Rule — now available beyond Income Tax. GST and Other Laws Available
2. New: “In Favour Of” filter added in Case Laws.
Try both these filters in Case Laws →
Press 'Enter' to add multiple search terms. Rules for Better Search
---------------- For section wise search only -----------------
Accuracy Level ~ 90%
of 
Press 'Enter' after typing page number.
of Press 'Enter' after typing page number.
No Folders have been created
Are you sure you want to delete "My most important" ?
NOTE:
of Press 'Enter' after typing page number.
of Press 'Enter' after typing page number.
All Case Laws
of Press 'Enter' after typing page number.
of Press 'Enter' after typing page number.
All Case Laws
Note
Bookmark
Share
Don't have an account? Register Here
of Press 'Enter' after typing page number.
<h1>Tribunal overturns interest charges for architectural services company; Precedents cited, orders in favor of assessee.</h1> The Tribunal allowed all 11 appeals regarding the charging of interest under section 234E for quarters relevant to assessment years 2013-14, 2014-15, and ... Charging of interest u/s.234E - assessee filed the TDS returns for the respective quarters belatedly -Liability of interest for periods prior to June 1, 2015 - HELD THAT:- Section 200A deals with processing of statements of tax deducted at source. Clause (c) of section 200A(1) was inserted by the Finance Act 2015 w.e.f. 01-06-2015 providing for the levy of fee u/s.234E of the Act. In that view of the matter, such fee u/s.234E can be levied only for the default committed after 01-06-2015 and not prior to that. In Olari Little Flower Kuries Pvt. Ltd. Vs. Union of India and others (2022 (2) TMI 1061 - KERALAHIGH COURT] has affirmed the non-imposition of fee for the period prior to 01-06-2015. Similar view has been taken in Jiji Varghese [2022 (3) TMI 1291 - KERALA HIGH COURT] holding that no interest u/s 234E can be imposed for the periods of the respective A.Ys. prior to June 1, 2015. Thus, it is seen that the issue raised in these appeals is covered in favour of the assessee. Issues:Charging of interest u/s.234E for quarters relevant to assessment years 2013-14, 2014-15, and 2015-16.Analysis:The appeals arose from orders by the National Faceless Appeal Centre (NFAC), Delhi, regarding the imposition of interest u/s.234E. The assessee, a company providing architectural services, filed TDS returns belatedly, leading to the Assessing Officer (AO) levying late fees. The issue raised in all appeals was the confirmation of the fee u/s.234E. Section 200A of the Income-tax Act, 1961, deals with processing TDS statements, with clause (c) inserted by the Finance Act 2015, allowing the levy of fee u/s.234E from 01-06-2015. Precedents like Olari Little Flower Kuries Pvt. Ltd. Vs. Union of India and Jiji Varghese Vs. ITO(TDS) & Ors. held that no interest u/s 234E could be imposed for periods before June 1, 2015. Consequently, the Tribunal overturned the orders in favor of the assessee.Outcome:All 11 appeals were allowed, with the Tribunal pronouncing the order on 8th March 2023.
TaxTMI 
TaxTMI 
