Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
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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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