2025 (1) TMI 1183

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....Act, 1961 (in short 'the Act'). The only issue raised in these appeals is the charging of interest u/s.234E for the quarters arising in Assessment Years 2013-14, 2014-15, 2015-16 and 2016-17. 2. Identical grounds have been raised by assessee in all these appeals. We therefore proceed to dispose of these appeals by this consolidated order for the sake of convenience. 3. Brief facts common to these appeals are that TDS returns for the assessment years 2013-14, 2014-15, 2015-16 and 2016-17 corresponding to respective quarters captioned above were filed belatedly. The same were processed by Central Processing Cell (in short "CPC") u/s.200A levying fee u/s.234E of the Act. The assessee filed rectification applications u/s.154 of the Act fo....

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....Act only after 01.06.2015. In that view of the matter, Revenue authorities are empowered to impose such late fee u/s.234E 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 Pvt. Ltd. Vs. Union of India and others (2022) 440 ITR 26 (Kerala) has affirmed the non-imposition of fee for the period prior to 01.06.2015. Similar view has been taken in Jiji Varghese VS. ITO(TDS) & Ors. (2022) 443 ITR 267 (Ker) holding that no fee u/s.234E can be imposed for the periods of the respective A.Ys. prior to 1st June, 2015. Similar view was also taken by this Tribunal in the case of Dadasaheb Vitthalrao Urhe Vs. ITO (TDS), Pune in ITA Nos.1286 to 1309/PUN/2023, dated 29.02.2024....