TaxTMI 
TaxTMI 
2022 (6) TMI 1494
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.... /2022, 205 to 207/CHD /2022, 208 & 209/CHD /2022, 210 & 211/CHD /2022, 212/CHD /2022, 213/CHD /2022, 214 & 215/CHD /2022, 216/CHD /2022, 217 & 218/CHD /2022, 219 to 221/CHD /2022, 222/CHD /2022, 223 to 225/CHD /2022, 226/CHD /2022, 227 to 228/CHD /2022, 229/CHD /2022, 230/CHD /2022, 231 & 232/CHD /2022, 233/CHD /2022, 234 & 235/CHD /2022, 236 & 237/CHD /2022, 238/CHD /2022, 239/CHD /2022, 240 & 241/CHD /2022, 242/CHD /2022, 243 & 244/CHD /2022, 245 & 246/CHD /2022, 247/CHD /2022, 248 & 249/CHD /2022, 250/CHD /2022, 251 to 253/CHD /2022, 254 & 255/CHD/ 2022, 256 & 257/CHD/ 2022, 258 & 259/CHD/ 2022, 260/CHD/2022, 261 & 262/CHD/ 2022, 263 & 264/CHD/ 2022, 265 to 267/CHD/ 2022 SHRI N.K. SAINI, VICE PRESIDENT AND SHRI SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER For the Assessee by : Sh. Pratik Sadrani, CA For the Revenue by : Smt. Priyanka Dhar, Sr. DR PER BENCH: These bunch of appeals have been preferred by the captioned Assessees against the respective orders of the National Faceless Appeal Centre (NFAC), Delhi as per the details given below:- ITA Nos. Appeal by CIT(A) / NFAC order dated 105/Chd/ 2022 to 235/Chd/2022 Assessee 28.09.2021 236/Chd/2022 ....
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....ead Office level, the relevant information to reach from the remotest of branches was also difficult at times and the required information and documents would reach the Head office only after considerable delay which resulted in the Head office being unable to compile and consolidate all the appeals to be filed before this Tribunal within the prescribed time limit which resulted in the late filings of the appeals before the ITAT. The Ld. AR submitted that there was no intentional delay on the part of the assessee in this regard and the delay occurred due to circumstances beyond the control of the assessee-Branches as well as the Head office. The Ld. AR submitted that these Branches being part of a Regional Rural Bank (RRB) were also not equipped with the State of Art Communication Equipment like high-speed internet and computers etc. Thus, all these factors went into causing delay in late filing of the appeals. The Ld. AR prayed that in the interest of substantial justice, the captioned appeals should be admitted to be heard on merits. 4.0 Per contra, the Ld. Sr.DR opposed the assessee's prayer for condonation of delay and submitted that the provisions of Income Tax law are the ....
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....cs, but seek their remedy promptly. The object of providing a legal remedy is to repair the damage caused by reason of legal injury. The law of limitation fixes a lifespan for such legal remedy for the redress of the legal injury so suffered. Time is precious and wasted time would never revisit. During the efflux of time, newer causes would sprout up necessitating newer persons to seek legal remedy by approaching the courts. So a lifespan must be fixed for each remedy. Unending period for launching the remedy may lead to unending uncertainty and consequential anarchy. The law of limitation is thus founded on public policy. It is enshrined in the maxim interest reipublicae up sit finis litium (it is for the general welfare that a period be put to litigation). Rules of limitation are not meant to destroy the rights of the parties. They are meant to see that parties do not resort to dilatory tactics but seek their remedy promptly. The idea is that every legal remedy must be kept alive for a legislatively fixed period of time." As pointed out earlier, an appeal under Section 96 CPC is a statutory right. Generally, delays in preferring appeals are required to be condoned, in th....
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....the NFAC was factually incorrect because the assessee had preferred appeal against the intimation passed u/s 154 of the Income Tax Act, 1961 which was received by the assessee on 02.04.2021 and, thereafter, the appeal had been filed before the NFAC on 16.04.2021 which was even apparent from the paragraph 1 of the order of the NFAC. It was submitted that, the appeal before the NFAC had been filed within the prescribed period of 30 days and, thus, the NFAC had grossly mis-appreciated the facts by dismissing the appeal of the assessee as being not maintainable in view of the alleged inordinate delay in filing the appeal before it. 6.1 The Ld. AR further submitted that there was a mistake apparent from the record which the assessee had sought to be rectified because the late filing fee u/s 234E had been levied on various assessees for the periods which were prior to 01.06.2015 which was in the very teeth of the various judicial pronouncements across the country wherein it had been held that no late fee was leviable u/s 234E for periods prior to 1st June, 2015. The Ld. AR drew our attention to a paper book containing numerous judicial precedents in favour of the assessee wherein it h....
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....ed that the assessee has not demonstrated with cogent evidence that how the original order passed u/s 200A of the Act was rectifiable in terms of section 154 of the Act. It was further argued that the assessee has not demonstrated before the NFAC how various case laws supported its case, therefore, the NFAC could not be said to have committed an error in dismissing the assessee's appeal. The Ld. AR also submitted that there were 383 appeals on the issue filed by the various Branches of the Bank and out of these 192 appeals were decided by the NFAC in the favour of the assessee and 28 appeals were still in the process of hearing while 163 appeals which were dismissed were now before the Tribunal. The Ld. AR placed a copy of the order of the NFAC in the case of Chamba Branch of the Bank for assessment year 2015-16 and submitted that here the NFAC had accepted the assessee's appeal u/s 154 of the Act and had allowed the assessee's appeal by holding that no late fee was leviable u/s 234E of the Act. It was submitted that there were 191 similar orders and, thus, apparently there was a diversion in the view taken by the NFAC on the issue. 8.0 We have heard the rival submissions and ha....
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....gainst the order passed under section 154 of the Act. The CIT(A) had noted that rectification application was filed in February, 2018 which was rejected by CPC on the same day. The CIT(A) was of the view that there was no merit in condonation of delay, wherein appeals were filed beyond the period prescribed. The assessee had filed appeals against the order passed under section 154 of the Act, hence the time period of appeals filed by assessee before the CIT(A) have to be computed from the date of order passed under section 154 of the Act and not from the date of issue of intimation. Thus, there is no merit in the order of CIT (A) in dismissing the appeals of assessee on this issue. " 8.4 Therefore, in view of the above order of the ITAT Pune Bench, we also hold that the NFAC had erred in dismissing the appeals of the assessees as being time-arred by taking the date of intimation u/s 200A of the Act as the basis for computing the limitation period for filing the appeal. The NFAC should have taken the date of intimation u/s 154 of the Act for the purpose of computing the limitation period. Admittedly, and, undisputedly, the appeals before the NFAC were within time if we take the d....
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....ws that the date of order u/s 200A was 11.11.2013 and the assessee filed the rectification application before the CPC and the order u/s 154 was passed on 11.02.2019. The assessee has filed the appeal against the order passed u/s 154 on 02.03.2019 which is well within the time. Even the ld.CIT(A) at para 4.2 of his order has also mentioned that the assessee has filed the appeal against the correction dated 11.02.2019. However, the ld.CIT(A), without considering the facts properly, has held that there is inordinate delay in filing of the appeals before him and the assessee failed to submit explanation so as to justify the above delay for which he dismissed the appeals on account of delay in filing these appeals. In our opinion, there is no delay in the instant case and all these confusion arose because of some typographical error in the Form 35 where the assessee, instead of mentioning section 154, mentioned section 200A against the section and subsection of the Income-tax Act, 1961. We, therefore, find merit in the argument of the ld. Counsel that there is no delay in filing of the above appeals. 23. Further, the Hon'ble Delhi High Court in the case of Remfry and Sons (supr....
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....rat High Court in Rajesh Kourani vs Union of India (supra) and applying the proposition that where there was difference of opinion between Hon'ble High Courts on a particular issue and in the absence of any decision rendered by the Jurisdictional High Court, then the decision in favour of the assessee needs to be followed as held by Hon'ble Supreme Court in Vegetables Products Ltd. [1973] 88 ITR 192(SC). The relevant findings of the Tribunal are as under:- 11. "We have heard the rival contentions and perused the record. The issue arising in the present bunch of appeals is against levy of late filing fees under section 234E of the Act while issuing intimation under section 200A of the Act, in the first bunch of appeals. The second bunch of appeals in the case of Junagade Healthcare Pvt. Ltd. is against order of Assessing Officer passed under section 154 of the Act rejecting rectification application moved by assessee against intimation issued levying late filing fees charged under section 234E of the Act. The case of assessee before us is that the issue is squarely covered by various orders of Tribunal, wherein the issue has been decided in respect of levy of....
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....tion of fee and failure for payment of fee under Section 200A which has been brought about with effect from 1.6.2015 cannot be said as only by way of a regulatory mode or a regulatory mechanism but it can rather be termed as conferring substantive power upon the authority. It is true that, a regulatory mechanism by insertion of any provision made in the statute book, may have a retroactive character but, whether such provision provides for a mere regulatory mechanism or confers substantive power upon the authority would also be a aspect which may be required to be considered before such provisions is held to be retroactive in nature. Further, when any provision is inserted for liability to pay any tax or the fee by way of compensatory in nature or fee independently simultaneously mode and the manner of its enforceability is also required to be considered and examined. Not only that, but, if the mode and the manner is not expressly prescribed, the provisions may also be vulnerable. All such aspects will be required to be considered before one considers regulatory mechanism or provision for regulating the mode and the manner of recovery and its enforceability as retroactive. If at th....
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....d for computation of fees and failure for payment of fees under section 200A of the Act which was brought on Statute w.e.f. 01.06.2015. The said amendment was held to be prospective in nature and hence, notices issued under section 200A of the Act for computation and intimation for payment of late filing fees under section 234E of the Act relating to the period of tax deduction prior to 01.06.2015 were not maintainable and were set aside by the Hon'ble High Court. In view of said proposition being laid down by the Hon'ble High Court of Karnataka (supra), there is no merit in observations of CIT(A) that in the present case, where the returns of TDS were filed for each of the quarters after 1st day of June, 2015 and even the order charging late filing fees was passed after June, 2015, then the same are maintainable, since the amendment had come into effect. The CIT(A) has overlooked the fact that notices under section 200A of the Act were issued for computing and charging late filing fees under section 234E of the Act for the period of tax deducted prior to 1st day of June, 2015. The same cannot be charged by issue of notices after 1st day of June, 2015 even where the returns were fi....
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.... duly noting that although the Hon'ble Gujarat High Court in the case of Rajesh Kourani Vs. UOI (supra) has held against the assessee on the issue, we draw support from the ratio laid down by the Hon'ble Apex Court in the case of CIT Vs. Vegetable Products (supra) wherein it has been held that in case of diversity of opinion, the view favoring the assessee should be followed. 8.8 Before parting, we would also like to make a reference to the order of the NFAC dated 25.08.2021 which has been passed in the case of Chamba Branch of HPGB wherein the NFAC has accepted and allowed the assessee's appeal preferred against intimation u/s section 154 of the Act and has deleted the late fee levied u/s 234E of the Act by following the judgement of the Hon'ble Karnataka High Court in the case of Fatheraj Singhvi & Ors Vs. Union of India (supra). The Ld. AR has stated at the Bar that this order was part of 192 appeals in respect of the various Branches of HPGB on identical issue challenging the rejection of assessee's applications u/s 154 of the Act. Thus, apparently, the NFAC has taken divergent views on the same issue when rejecting 163 appeals of the HPGB and allowing 192 appeal....
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.... 119/CHANDI/2022 ro Hamirpur, Branch ITA 120/CHANDU/2022 ro Hamirpur, Branch ITA 121/CHANDI/2022 Badukhar, Branch 122/CHANDI/2022 ITA 123/CHANDI/2022 Badukhar, Branch PTLH10975G 2012-13 PTLH10975G 2012-13 PTLH10965D 2012-13 Q2 PTLH10965D 2013-14 101 PTLH10958D 2012-13 Q2 PTLH10958D 2012-13 02 PTLH10956D 2012-13 Q3 PTLH10958D 2013-14 PTLH10958D 2013-14 PTLH10958D 2013-14 PTLH10958D 2013-14 2013-14 Q1 Q1 Q2 loa Q2 Q2 Q3 PTLH10975G 2013-14 Q1 PTLH10982G 2012-13 102 02 PTLH10982G 2012-13 HGB-HARCHAKIAN 24 25 26 ITA 128/CHANDI/2022 KANGRA Branch ITA 129/CHANDI/2022 KANGRA Branch ITA 130/CHANDI/2022 Sarkaghat, Mandi, Branch Sajaopiploo HGB-HARCHAKIAN Sajaopiploo Q3 PTLH10982G 2012-13 Q4 PTLH10982G 2013-14 Q1 PTLH11097C 2012-13 Q3 PILH11097C 2013-14 101 PTLH11005B 2012-13 Q2 24Q 7200 PTLH11005B 2012-13 Q3 24Q 2800 240 3000 240 1800 240 1400 1400 21Q 1200 240 1400 260 1400 240 8800 260 6626 240 4500 24Q 4500 24Q 6000 240 5200 240 5400 24Q 41400 240 8400 240 4600 240 14200 ITBA/NFAC/S/250/2021-22....
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....2012-13/10010704 ITBA/NFAIC/S/250/2021-22/1035967934(1) NFAC/2013-14/10010705 ITBA/NFAC/S/250/2021-22/1035967975(1) NFAC/2013-14/10010706 ITBA/NFAIC/S/250/2021-22/1035972029(1) NFAC/2012-13/10010749 HGB-THUNAG MANDI, PTLH11010G 2012-13 Q3 240 2000 ITBA/NFAC/S/250/2021-22/1035972077(1) NFAC/2012-13/10010750 35 ITA 139/CHANDI/2022 Branch HGB-THUNAG MANDI, PTLH11010G 2012-13 Q4 240 2800 ITBA/NFAIC/S/250/2021-22/1035972092(1) NFAC/2012-13/10010751 36 38 ITA 140/CHANDI/2022 Branch 37 ITA 141/CHANDI/2022 Branch ITA 142NCHANDI/2022 Branch HGB-THUNAG MANDI PTLH11010G 2013-14 Q1 240 6000 ITBA/NFAIC/S/250/2021-22/1035972136(1) NFAC/2013-14/10010752 HGB-THUNAG MANDI 39 HGB-JALGKANG JAISINGHPUR KANGRA PTLH11010G 2013-14 Q2 240 4800 PTLH10994E 2012-13 Q2 240 3400 ITBA/NFAIC/S/250/2021-22/1035972154(1) NFAC/2013-14/10010753 ITBA/NFAIC/S/250/2021-22/1035970125(1) NFAC/2012-13/10010726 ITA 143/CHANDI/2022 Branch 40 HGB-JALGKANG JAISINGHPUR KANGRA PTLH10994E 2012-13 Q3 240 7200 ITBA/NFAIC/S/250/2021-22/1035970271(1) NFAC/2012-13/10010727 ITA 144/CHANDI/2022 Branch 41 HGB-JALGKANG JAISINGHP....
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..../CHANDI/2022 KANGRA, Branch Mahadev, Sundernagar, Mahadev, Sundernagar, Mahadev, Sundernagar, PTLH10972D 2013-14 Q1 240 9400 PTLH10972D 2012-13 Q3 240 4600 PTLH11282F 2012-13 Q2 24Q 8000 PTLH11282F 2012-13 Q3 24Q 4000 PTLH11282F 2013-14 Q1 24Q 8000 PTLH11147D 2012-13 ITBAINFAC/S/250/2021-22/1035968561(1) NFAC/2013-14/10010713 ITBAINFAC/S/250/2021-22/1035968481(1) NFAC/2012-13/10010712 ITBAINFAC/S/250/2021-22/1035976147(1) NFAC/2012-13/10010806 ITBA/NFAC/S/250/2021-22/1035976286(1) NFAC/2012-13/10010831 ITBAINFAC/S/250/2021-22/1035976014(1) NFAC/2013-14/10010833 Q2 24Q 10600 ITBA/NFAC/S/250/2021-22/1035975897(1) NFAC/2012-13/10010789 24Q 15400 ITBA/NFAC/S/250/2021-22/1035-969193(1) NFAC/2012-13/10010788 58 59 ITA 162/CHANDI/2022 Branch ITA 163/CHANDI/2022 Branch 60 ITA 164/CHANDI/2022 Branch Mahadev, Sundernagar, PTLH11147D 2012-13 Q3 PTLH11147D 2012-13 04 PTLH11147D 2013-14 Q1 240 26000 240 3000 ITBA/NFAC/S/250/2021-22/1035969308(1) NFAC/2012-13/10010790 ITBA/NFAC/S/250/2021-22/1035 969430(1) NFAC/2013-14/10010792 61 ITA 165/CHANDI/2022 Branch Mahadev, Sundernagar, PTLH11147D 2013-14 ....
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....TA 179/CHANDU/2022 Branch HGB-PALAMPUR JAISINGHPUR KANGRA ITA 180/CHANDI/2022 Branch HGB-PALAMPUR JAISINGHPUR KANGRA ITA 181/CHANDI/2022 Branch ITA 182/CHANDU/2022 KANGRA Branch ITA 183/CHANDI/2022 KANGRA, Branch ITA 184/CHANDI/2022 KANGRA Branch ITA 185/CHANDI/2022 KANGRA Branch ITA 186/CHANDU/2022 KANGRA, Branch PTLH11002F 2012-13 03 240 7200 ITBA/NFAC/S/250/2021-22/1035971444(1) NFAC/2012-13/10010736 PTLH11002F 2012-13 Q4 240 21400 ITBA/NFAC/S/250/2021-22/1035971472(1) NFAC/2012-13/10010737 PTLH11002F 2013-14 Q1 24Q 13500 ITBAINFAC/S/250/2021-22/1035971509(1) NFAC/2013-14/10010738 PTLH11307C 2012-13 02 240 5000 ITBAINFAC/S/250/2021-22/1035976040(1) NFAC/2012-13/10010834 HGB-DARI DHARMSHALA PTLH11307C 2012-13 Q4 240 4000 ITBAINFAC/S/250/2021-22/1035976261(1) NFAC/2012-13/10010835 HGB-DARI DHARMSHALA PTLH11307C 2012-13 04 260 4000 ITBAINFAC/S/250/2021-22/1035976338(1) NFAC/2012-13/10010836 HGB-DARI DHARMSHALA PTLH11307C 2013-14 Q1 240 8600 ITBAINFAC/S/250/2021-22/1035976402(1) NFAC/2013-14/10010837 HGB-DARI DHARMSHALA PTLH11307C 2013-14 02 240 7000 ITBAINFAC/S/250/2021-221035976697(1) NFAC/20....
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....DI/2022 Branch 99 ITA 203/CHANDI/2022 Branch 100 101 ITA 205/CHANDI/2022 Koti, Mandi, Branch 102 ITA 206/CHANDI/2022 Koti, Mandi, Branch 103 ITA 207/CHANDI/2022 Kotli Mandi, Branch 104 ITA 208/CHANDI/20:22 Kotli, Mandi, Branch 105 ITA 209/CHANDI/2022 Koti, Mandi, Branch 106 ITA 210/CHANDI/2022 Dharampur Mandi, Branch 107 ITA 211/CHANDI/2022 Dharampur Mandi, Branch 108 ITA 212/CHANDI/20/22 Dharampur Mand, Branch PTLH11133D 2013-14 02 240 7400 PTLH11187B 2012-13 Q3 240 7600 ITBAINFAC/S/250/2021-22/1035973226(1) NFAC/2013-14/10010774 ITBAINFAC/S/250/2021-22/1035977644(1) NFAC/2012-13/10010821 ITBAINFAC/S/250/2021-22/1035977570(1) NFAC/2013-14/10010822 ITBAINFAC/S/250/2021-22/1035977477(1) NFAC/2013-14/10010823 ITBAINFAC/S/250/2021-22/1035971583(1) NFAC/2013-14/10010739 HGB-CHARRI KANGRA ITA/204/CHANDI/2022 Branch HGB-BHAROLI KANGRA PTLH11187B 2013-14 Q3 240 9000 PTLH11003G 2013-14 Q1 240 14200 PTLH11136G 2012-13 Q2 240 3000 PTLH11136G 2012-13 Q3 24Q 1200 PTLH11136G 2012-13 Q4 240 3200 PTLH11136G 2013-14 Q1 240 9000 PTLH11136G 2013-14 Q2 240 5000 109 ITA 213/CHANDI/2022 Randhara, Ma....
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.... Mand, Branch PTLH109090 2012-13 Q2 240 4200 PTLH109090 2012-13 240 14800 ITBAINFAC/S/250/2021-22/103596687301) NFAC/2013-14/10010694 240 5000 PTLH10909D 2012-13 Q4 240 4400 PTLH10909D 2013-14 PTLH11177F 2012-13 Q2 240 4000 PTLH11177F 2012-13 Q4 240 11000 ITBAINFAC/S/250/2021-22/1035973440(1) NFAC/2012-13/10010801 ITBAINFAC/S/250/2021-22/1035970367(1) NFAC/2012-13/10010802 ITBAINFAC/S/250/2021-22/1035 966590(1) NFAC/2012-13/10010691 ITBAINFAC/S/250/2021-22/1035 966676(1) NFAC/2012-13/10010692 ITBAINFAC/S/250/2021-22/1035966793(1) NFAC/2012-13/10010693 PTLH10960F 2012-13 Q2 240 5200 ITBAINFAC/S/250/2021-22/1035968014(1) NFAC/2012-13/10010707 HGB-BHUANA KANGRA PTLH11134E 2012-13 02 240 2000 ITBAINFAC/S/250/2021-22/1035973290(1) NFAC/2012-13/10010775 HGB-BHUANA KANGRA PTLH11134E 2012-13 Q3 240 2800 ITBAINFAC/S/250/2021-22/1035978888(1) NFAC/2012-13/10010856 HGB-BHUANA KANGRA PTLH11134E 2013-14 Q1 240 6000 ITBAINFAC/S/250/2021-22/1035973333(1) NFAC/2013-14/10010776 Amt of Appeal No. of ITAT Sr.No. Name of Branch of Himachal Pradesh Levy uls Appeal TAN of Financial Branch Year m Appeal Number of CIT ....
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....NFAC/2013-14/10010811 ITBA/NFAC/S/250/2021-22/1035977844(1) NFAC/2012-13/10010851 ITBA/NFAC/S/250/2021-22/1035977939(1) NFAC/2012-13/10010852 HGB-BO BAROH KANGRA PTLH11450F 2012-13 Q2 24Q 3400 141 142 143 144 ITA 248/CHANDI/2022 Branch 145 ITA 249/CHANDI/2022 Branch 146 ITA 250/CHANDI/2022 Branch 147 148 149 HGB-BO BAROH KANGRA PTLH11450F 2012-13 Q3 24Q 4600 ITBA/NFAC/S/250/2021-22/1035978066(1) NFAC/2013-14/10010853 HGB-BO BAROH KANGRA PTLH11450F 2013-14 Q1 240 9200 PTLH11109A 2012-13 Q2 24Q 3400 ITBA/NFAC/S/250/2021-22/1035972606(1) NFAC/2012-13/10010762 HGB-BATHUTIPRI JASWAN ITA 251/CHANDI/2022 KANGRA Branch HGB-BATHUTIPRI JASWAN ITA 252/CHANDI/2022 KANGRA Branch HGB-BATHUTIPRI JASWAN ITA 253/CHANDI/2022 KANGRA Branch HGB-BATHUTIPRI JASWAN 150 ITA 254/CHANDI/2022 KANGRA, Branch PTLH11109A 2012-13 Q2 260 2692 ITBA/NFAC/S/250/2021-22/1035972529(1) NFAC/2012-13/10010760 PTLH11109A 2012-13 Q3 24Q 6200 ITBA/NFAC/S/250/2021-22/1035972583(1) NFAC/2012-13/10010761 PTLH11109A 2013-14 Q1 240 8500 ITBA/NFAC/S/250/2021-22/1035972637(1) NFAC/2013-14/10010763 Sr.No. Appeal No. of ITAT 151 152....