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    <title>2024 (7) TMI 33 - ITAT CHENNAI</title>
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    <description>Late fee under section 234E could not be computed and recovered through intimation under section 200A for TDS statements relating to periods before 1 June 2015, because the processing machinery in section 200A did not then include clause (c) authorising such levy at the intimation stage. The amendment inserting that clause was treated as the enabling provision for computation of the fee during processing, and it was not available for earlier periods. Relying on binding jurisdictional precedent and a coordinate bench view, the Tribunal treated the late-fee demand in the pre-1 June 2015 intimation as authority and directed deletion.</description>
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      <description>Late fee under section 234E could not be computed and recovered through intimation under section 200A for TDS statements relating to periods before 1 June 2015, because the processing machinery in section 200A did not then include clause (c) authorising such levy at the intimation stage. The amendment inserting that clause was treated as the enabling provision for computation of the fee during processing, and it was not available for earlier periods. Relying on binding jurisdictional precedent and a coordinate bench view, the Tribunal treated the late-fee demand in the pre-1 June 2015 intimation as authority and directed deletion.</description>
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