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Rectification u/s 154: Challenging Improper Late Fees u/s 234E for Pre-June 1, 2015 Periods.
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....Rectification of mistake u/s 154 - levying late-fee u/s 234E which was not leviable for period prior to 01.06.2015 - We find that it is not a case of revenue that the rectification-application u/s 154 against the intimation u/s 200A is absolutely barred in the scheme of the Act. We also observe that when the late-fee is not leviable in the law and on facts, by levying the same the assessees have been fastened with the liability beyond and against the scheme of the Act, which should not happen. - AT....