Late Fee u/s 234E Can't Be Contested Without Proving Assessing Officer Breached Section 200A Provisions.

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....Levy of late fee u/s 234E - The order of the A.O. can be challenged only if the A.O. has failed to comply with the mandatory provisions of Section 200A r.w.s. 234E of the Act while making adjustment and issuing the intimation. In absence of any such allegation by the assessee that the A.O. has violated any of the provisions of Section 200A as well as Section 234E adjustment made by the A.O. on account of late fee U/s 234E of the Act cannot be deleted. - AT....