2021 (6) TMI 837

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....3 Rs. 49,540 2014-15 26Q-1 Rs. 98,560 2014-15 24Q-2 Rs. 77,060 2014-15 26Q-3 Rs. 56,320 2014-15 26Q-4 Rs. 50,690 2013-14 26Q-2 Rs. 42,800 2. The brief facts of the case are that the appellant, an individual, was the proprietor of a concern identified as 'Imaginary Friend Pictures' which was stated to be engaged in the business of production of advertisement films. The CPC Bangalore levied the aforesaid interest under Section 234E of the Act. The other aspects of the case emanating out of the submission of the assessee before the learned CIT(A) as are under :- "2. The appellant vide letters dated 04.05.2019 and 15.05.2019 submitted that he was required to deduct tax at source on various payments made and, accordingly, he d....

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.... Vs CIT TDS Ghaziabad ITA No. 4071/M/2015 xiii) Medical Engineers (India) Ltd. Vs CIT TDS Ghaziabad ITA No. 4072/M/2013 xiv) Roha Dry Chem Pvt. Ltd. Vs DCIT(TDS) ITA No. 2971, 2972, 2973/M/2013 xv) Diamond Ship Brokers Pvt. Ltd. Vs ITO TDS ITA No. 4127, 4128, 4129/M/2015 xvi) Bhoja Vittal Shetty Vs ITO 1(2)(1) Mumbai ITA No. 4127, 4128, 4129/M/2015 xvii) Hitesh Shankar Shetty Vs DCIT(TDS) CPC ITA No. 3962, 3963/M/2015 xviii) Bhaskar Krishna Shetty Vs DCIT(TDS) CPC ITA No. 3964, 3965/M/2015 xix) Dinesh Kumar S Gupta Vs Vs DCIT(TDS) CPC ITA No. 4088/M/2015 xx) Arpana Motars Pvt. Ltd. Vs Vs DCIT(TDS) CPC ITA No. 4175, 4176/M/2015 2.1 As regards the delay in filing of appeal, the appellant stated that he initially received the....

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....that there was a delay in filing the appeals as under :- Form No. A.Y/quarter First CPC intimation date Due date of filing appeal Date of appeal filing Delay (Days) 26Q 2014-15(Q-3) 27.08.2014 26.09.2014 02.05.2018 1314 26Q 2013-14(Q-3) 01.09.2013 01.10.2013 30.04.2018 1672 26Q 2014-15(Q-1) 07.08.2014 06.09.2014 27.04.2018 1329 26Q 2014-15(Q-2) 15.08.2014 14.09.2014 27.04.2018 1321 26Q 2014-15(Q-4) 02.12.2014 01.01.2015 02.05.2018 1217 26Q 2013-14(Q-2) 14.06.2013 14.07.2013 27.04.2018 1746 Learned CIT(A) was of the opinion that the delay was not to be condoned. After having not condoned the delay in filing the appeal against the original order, he further held that this is an appeal against order u....

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....eals are treated to be filed under section 200A of the Act, these are hugely belated as tabulated above, for which no reasonable cause has been shown or established. For these reasons, the appeals are to be dismissed unadmitted." Against the order, assessee is in appeal before us. 4. We have heard both the parties and perused the record. As evident from the aforesaid facts narrated above, the crux of the matter was levy of fee/interest under Section 234E of the Act by the CPC, Bangalore. As evident from the case laws referred above, the enabling provision for levy of fee/interest was not in the statute books at that time and hence, the assessee filed a rectification application under Section 154 of the Act. The 154 application was rejecte....