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Issues: Whether late fee under Section 234E of the Income-tax Act, 1961 could be levied for delayed filing of TDS statements and whether such levy was saved by reasonable cause.
Analysis: Section 200(3) requires furnishing of TDS statements within the prescribed time. On delay, late fee is chargeable under Section 234E. Section 273B does not extend reasonable cause protection to such levy. The delay, therefore, does not dilute the statutory levy, which operates automatically on default in filing within time.
Conclusion: The late fee under Section 234E was rightly levied and the challenge to the levy failed.