Section 234E fee can be levied through TDS processing under section 200A for delays after the amendment took effect.

Fee under section 234E for default in furnishing a TDS statement was computable through processing under section 200A where the delay fell after 1 June 2015, because the amended processing provision then enabled fee determination and intimation at the processing stage. Section 234E was treated as the charging provision and section 200A as the machinery provision, so the levy was upheld and the challenge failed.

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Issues: Whether fee under section 234E could be levied through processing under section 200A in respect of delayed filing of the TDS statement for a period falling after 01.06.2015.

Analysis: The TDS statement was filed belatedly after tax deduction and deposit in relation to transfer of immovable property. Section 234E creates liability for default in furnishing the TDS statement, while the amendment to section 200A with effect from 01.06.2015 enabled computation of such fee at the time of processing and issuance of intimation. Since the relevant period was after the effective date of the amendment, the fee was held to be computable under the processing mechanism. The cited judicial position treating section 234E as a charging provision and section 200A as a machinery provision supported the levy.

Conclusion: The levy of fee under section 234E was upheld and the assessee's challenge failed.

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