Late Fee u/s 234E Invalid Before 01.06.2015, Tribunal Rules in Favor of Assessee for Tax Years 2013-14 & 2015-16.

The ITAT allowed the assessee's appeals, ruling that the late fee levied under Section 234E read with Section 200A of the Income Tax Act, 1961, was invalid for the assessment years 2013-14 and 2015-16. The Tribunal set aside the CIT(A)'s order, emphasizing that the authorities lacked the power to impose such fees before 01.06.2015.

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Issues Involved:
The judgment involves the challenge to the orders of the learned Commissioner of Income-tax (Appeals) by the assessee regarding the late fee levied under section 234E read with section 200A of the Income Tax Act, 1961 for the assessment years 2013-14 and 2015-16.

Late Fee Levied under Section 234E:
The Tribunal considered the sole issue of the levy of late fee under section 234E in these appeals. It was noted that the Tribunal had previously ruled in favor of the assessee in a similar case for the assessment year 2015-16. The Tribunal observed that the authorities did not have the power to impose the late fee under section 234E for the relevant assessment years prior to the introduction of section 200A(1)(c) of the Act. The Tribunal relied on the judgment of the Hon'ble High Court of Madras in a similar case to support its decision. It was emphasized that no late fee under section 234E could be imposed before 01.06.2015. The Tribunal referred to various judgments to support its conclusion and ultimately held that the late fee levied on the assessee was invalid and deserved to be deleted. Consequently, the Tribunal set aside the order of the learned CIT(A) and deleted the late fee levied under section 234E read with section 200A for the respective quarters in question.

Judgment Outcome:
In light of the above analysis and the precedent set in the assessee's own case for the assessment year 2015-16, the Tribunal allowed the appeals of the assessee by deleting the late fee levied under section 234E read with section 200A of the Income Tax Act, 1961 for the relevant quarters. The impugned order of the learned CIT(A) was set aside, and the Tribunal ruled in favor of the assessee.

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