Late Fee for Delayed TDS Filing u/s 234E Cannot Be Applied Retroactively Before June 1, 2015.

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....Late fee u/s 234E - Late filing of TDS return - the provision of Section 234E of the Act is charging provision i.e. substantive provision which could not be applied retrospectively, unless it is expressly provided in the Act, to levy the late fee for any delay in filing the TDS statement for the period prior to 01.06.2015. The counsel for the assessee has rightly contended that in the absence of enabling provisions u/s 200A of the Act, such levy of late fee is not valid - AT....