Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
The pre-amended Section 200A of the Income Tax Act did not permit processing of TDS statements for default in payment of late fee u/s 234E. Hence, late fee charged for belated filing of TDS quarterly returns could not be recovered through processing u/s 200A. As per Karnataka Grameen Bank case, the amendment allowing imposition of fee u/s 234E during processing u/s 200A came into effect from 01.06.2015 with prospective effect. Therefore, levy of late fee u/s 234E would be illegal for TDS statements pertaining to periods prior to 01.06.2015. Consequently, the demand raised with reference to Section 234E cannot be countenanced under the pre-amended provision of Section 200A and requires quashing.
The pre-amended Section 200A of the Income Tax Act did not permit processing of TDS statements for default in payment of late fee u/s 234E. Hence, late fee charged for belated filing of TDS quarterly returns could not be recovered through processing u/s 200A. As per Karnataka Grameen Bank case, the amendment allowing imposition of fee u/s 234E during processing u/s 200A came into effect from 01.06.2015 with prospective effect. Therefore, levy of late fee u/s 234E would be illegal for TDS statements pertaining to periods prior to 01.06.2015. Consequently, the demand raised with reference to Section 234E cannot be countenanced under the pre-amended provision of Section 200A and requires quashing.
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