2020 (11) TMI 48

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....ee has filed an application seeking condonation of delay supported by affidavit. On perusing such application and affidavit, we are of the view that the delay in filing the appeals was due to reasonable cause. Hence, condonation the delay, we admit the appeals for adjudication on merits. 3. Though, the assessee has raised several lengthy and argumentative grounds in the appeals, however, only common issue arising in all the appeals is with regard to fee levied under section 234E of the Act while processing the statements of tax deducted at source under section 200A of the Act for various quarters relating to Financial Year 2012-13, 2013-14 & 2014-15. 4. When the appeals were called for hearing, no one was present on behalf of assessee....

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....under section 234E of the Act. The reasoning on the basis of which ld. CIT(A) came to such conclusion is, since section 234E of the Act was in the statute much earlier, the amendment made to section 200A by inserting Clause-(1)(c) is only clarificatory in nature. 6. Having considered the submissions of ld. Departmental Representative, we find that section 234E of the Act contemplating levy of fee for late filing of TDS statement was introduced to the statute w.e.f 10.07.2012. However, no such corresponding amendment was made to section 200A of the Act empowering the authority concerned to levy fee under section 234E of the Act, while processing the TDS statement. By Finance Act 2015 Clause-(c) to section 200A(1) was introduced w.e.f. 01.....