https://www.taxtmi.com/caselaws?id=345346 The Gujarat HC upheld the validity of section 234E of the Income Tax Act, 1961 regarding levy of fees for default in furnishing statements. The court rejected challenges to rule 31A which grants government deductors 15 additional days compared to private assessees for filing TDS statements, finding this classification reasonable given the complex nature and volume of government transactions involving multiple agencies. The court held that section 234E creates the substantive charge for fees, while section 200A merely provides the machinery for computation. Fee under section 234E was always leviable even prior to the 2015 amendment to section 200A. The court distinguished between fee under section 234E and penalty under section 271H, treating them as independent levies. The Supreme Court precedent in B C Srinivasa Setty was held inapplicable as it dealt with capital gains taxation in different circumstances. Decision against assessee. en-us Tue, 20 Jun 2017 00:00:00 +0530 Fri, 31 Jul 2026 13:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=345346 The Gujarat HC upheld the validity of section 234E of the Income Tax Act, 1961 regarding levy of fees for default in furnishing statements. The court rejected challenges to rule 31A which grants government deductors 15 additional days compared to private assessees for filing TDS statements, finding this classification reasonable given the complex nature and volume of government transactions involving multiple agencies. The court held that section 234E creates the substantive charge for fees, while section 200A merely provides the machinery for computation. Fee under section 234E was always leviable even prior to the 2015 amendment to section 200A. The court distinguished between fee under section 234E and penalty under section 271H, treating them as independent levies. The Supreme Court precedent in B C Srinivasa Setty was held inapplicable as it dealt with capital gains taxation in different circumstances. Decision against assessee. Case-Laws Income Tax Tue, 20 Jun 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=345346