2023 (9) TMI 675

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..... For the Respondent : Shri Rishi Kumar Bisen, DR ORDER Per PARTHA SARATHI CHAUDHURY, JM: These appeals preferred by the different assessees emanates from the separates orders of National Faceless Appeal Centre [NFAC], Delhi, dated 31.03.2021, 31/03/201 & 21/09/2021 for A.Ys. 2013-14, 2014-15 & 2013-14 respectively, as per the grounds of appeals on record. 2. The only issue raised i....

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....essee. Ld. DR also did not raise any objection for condonation of delay. Hence, the delay in filing all these appeals is condoned and the cases were heard and adjudicated on merits. Since the facts and circumstances and issues in these appeals are absolutely similar and identical, all the matters were heard together and disposed off vide this consolidated order. 4. The brief facts of the case(s....

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....s inserted by Finance Act, 2015 w.e.f. 01/06/2015 providing for levy of fee u/sec. 234E of the Act. In that view of the matter, such fee u/sec. 234E can be levied only for the default committed after 01/06/2015 and not prior to that. The Hon'ble Kerala High Court in Olari Little Flower Kuries (P.) Ltd. v. UOI & Ors. (2022) 440 ITR 26 (Ker.) has confirmed the non-imposition of fee for the perio....