Prospective application of TDS late-fee computation under section 200A limits levy to the period after 01.06.2015.

The amendment to section 200A enabling computation of late fee under section 234E was treated as prospective from 01.06.2015. On that basis, an intimation under section 200A could not levy fee for TDS statement defaults relating to the period before 01.06.2015. Where the default continued beyond that date, the fee was to be recalculated only for the period from 01.06.2015 up to the date of filing or processing, as applicable. The pre-01.06.2015 levy was therefore not sustained, and the matter was remitted for fresh computation only for the post-01.06.2015 period.

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Issues: (i) Whether late fee under section 234E could be levied in an intimation under section 200A for TDS statements pertaining to a period before 01.06.2015, and whether the fee, if any, had to be recalculated only from 01.06.2015.

Analysis: The amendment to section 200A enabling computation of fee under section 234E was treated as prospective from 01.06.2015. On that basis, late fee could not be computed for the period prior to that date. For statements where the default continued beyond 01.06.2015, the fee was to be recomputed only for the period commencing from 01.06.2015 up to the date of filing or processing, as applicable.

Conclusion: The levy was not sustained for the pre-01.06.2015 period. The matter was set aside for fresh computation of fee, if any, only from 01.06.2015 onwards, and the appeals were partly allowed.

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