Late Filing Fees u/s 234E Unsustainable if Invoked Before June 1, 2015, Per Section 200A Provisions.

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....Late filing fee u/s 234E of the Act by passing the order u/s 200A - No doubt, provisions contained u/s 234E were inserted by the Finance Act, 2012 imposing a liability upon deductor where TDS statement/returns were filed belatedly to pay fee as per the said section, Assessing Officer is to collect said fee chargeable u/s 234E of the Act for which machinery provisions have been provided u/s 200A of the Act to be effective from 01.06.2015. When undisputedly A.O has not invoked the provisions contained u/s 234E prior to 1st June, 2015 as required u/s 200A the levy is not sustainable - AT....