2020 (12) TMI 765

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....-15(26Q-Q3), 2014-15(26Q-Q4), 2014-15(24Q-Q1), 2014-15(24Q-Q3), 2014-15(24Q-Q2), 2015-16(24Q-Q1), 2015-16(24Q-Q4), 2015-16(24Q-Q2), 2015-16(24Q-Q3), 2015-16(24Q-Q4), 2015-16(26Q-Q1), 2015-16(26Q-Q2), 2015-16(26Q-Q3), 2015-16(26Q-Q4). 2. As the facts and issues are identical in all these 20 appeals of assessee, they are heard together and are disposed off by this common order. 3. Mr. Arjunraj, represented on behalf of the assessee, and Mrs. Vijayaprabha represented on behalf of the Revenue. 4. It was submitted by the learned A.R. that the assessee had deducted TDS and filing electronically TDS return. The orders had been passed in levying late filing fee under Section 234E of the Act and demands were raised under Sections 200A and 1....

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....Clause (1)(C) of 234E for the levy of such fee while processing the statement of tax deducted at source. It was a prayer that the delay in filing of these appeals before the learned CIT(A) may be condoned and the issues in the appeal restored to the file of the learned CIT(A) for adjudication on merits. It was a further submission that under similar circumstances, the delay in filing of the appeals before the learned CIT(A) in the case of M/s. Thirumurugan Plastics P. Ltd., in I.T.A. No. Nos. 2969 to 2987/Chny/2019 for assessment years 2013-14 to 2015-16 had been condoned by the Tribunal vide order dated 27.12.2019 and the issues restored to the file of learned CIT(A) for adjudication on merits. 5. In reply, the Ld. D.R. submitted that t....

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....omply with the systemic changes in a reasonable manner. Atleast in those cases, like this case, where the demand made on the assessee is pending for long time and the assessee has not responded, the Revenue should also have used other mode of communication, mentioned in sub-section (1) to section 282 of the Act. In this case, the Revenue has not brought to our notice any such communication with the assessee. Considering the totality of the facts and circumstances, the reasons canvassed by the assessee towards the delay in filing the impugned appeals appears reasonable and sufficient on this count also and hence, we condone the delay in filing each of these appeals and remit these appeals back to the ld. CIT(A) for deciding each of them on m....