https://www.taxtmi.com/caselaws?id=444918 Late fee under Section 234E could not be computed or levied while processing TDS statements under Section 200A for assessment years before 01.06.2015, because the machinery provision in Section 200A(1)(c) came into force only from that date. Although Section 234E created the fee liability from 01.07.2012, the processing mechanism necessary to determine and impose the fee was absent for the earlier period. The later amendment was treated as supplying that missing mechanism, not as operating retrospectively. The impugned levy was therefore impermissible for the relevant earlier years and liable to be set aside. en-us Mon, 09 Oct 2023 00:00:00 +0530 Sat, 04 Apr 2026 13:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=444918 Late fee under Section 234E could not be computed or levied while processing TDS statements under Section 200A for assessment years before 01.06.2015, because the machinery provision in Section 200A(1)(c) came into force only from that date. Although Section 234E created the fee liability from 01.07.2012, the processing mechanism necessary to determine and impose the fee was absent for the earlier period. The later amendment was treated as supplying that missing mechanism, not as operating retrospectively. The impugned levy was therefore impermissible for the relevant earlier years and liable to be set aside. Case-Laws Income Tax Mon, 09 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=444918