Section 234E fee not leviable for pre-01.06.2015 TDS statement delays under section 200A processing

Fee under section 234E could not be levied through processing under section 200A for TDS statements relating to periods before 01.06.2015, because the statutory processing mechanism then in force did not authorise such fee. The Tribunal followed coordinate-bench and High Court authorities and treated the levy as not retrospectively applicable to those quarters, so the fee was deleted.

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Issues: Whether fee under section 234E of the Income-tax Act, 1961 could be levied for delay in filing TDS returns for periods prior to 01.06.2015 while processing the statement under section 200A of the Income-tax Act, 1961.

Analysis: The Tribunal followed its earlier coordinate-bench decisions and the supporting High Court authorities to hold that, for periods prior to 01.06.2015, the statutory mechanism under section 200A did not permit levy of fee under section 234E on processing of TDS statements. The levy was treated as not applicable retrospectively to the relevant quarters.

Conclusion: The fee levied under section 234E for the period prior to 01.06.2015 was held to be not leviable and was deleted.

Ratio Decidendi: Fee under section 234E cannot be imposed for delay in filing TDS returns for periods prior to 01.06.2015 through processing under section 200A.

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