Prospective operation of section 200A amendment bars late fee under section 234E for pre-01-06-2015 TDS returns.

Late filing fee under section 234E could not be levied through processing under section 200A for TDS returns relating to periods before 01-06-2015, because the amendment enabling such computation was held to operate prospectively. In the absence of a jurisdictional High Court ruling and amid conflicting High Court views, the interpretation favourable to the assessee was adopted, and the fee levied for the relevant pre-01-06-2015 quarters was deleted as unsustainable.

---

---

Issues: Whether late filing fee under section 234E could be levied through processing under section 200A for TDS returns pertaining to periods prior to 01-06-2015.

Analysis: The amendment to section 200A enabling computation of fee under section 234E was held to operate prospectively from 01-06-2015. In view of the contrary views of different High Courts and the absence of a jurisdictional High Court ruling, the interpretation favouring the assessee was adopted.

Conclusion: The impugned fee levied for the relevant quarters prior to 01-06-2015 was unsustainable and had to be deleted.

---