2025 (3) TMI 1463

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....tava - Ld. Sr. DR ORDER MANOJ KUMAR AGGARWAL (ACCOUNTANT MEMBER) 1. Aggrieved by levy of late filing fess u/s 234E qua TDS returns for various quarters of Assessment Year (AY) 2013-14, the assessee is in further appeal before us. The registry has noted a delay of 126 days in the appeals which stands condoned. 2. From the records, it emerges that the assessee was saddled with later filing fees ....

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....l validity of section 234E of the Act. Save and except to observe that the question of constitutional validity of section 234E of the Act before the Division Bench of this Court shall remain open and shall not be treated as concluded. 27. In view of the aforesaid observations and discussion, the impugned notices under section 200A of the Act for computation and intimation for payment of fee unde....

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....could be made for the TDS deducted for the respective Assessment Years prior to 01-06-2015. 4. The revenue has quoted the decision of Hon'ble High Court of Gujarat in the case of Rajesh Kourani vs. UOI (83 Taxmann.com 137) which has taken a contrary view. Since no decision of jurisdictional high court is been shown to us, we follow the analogy of decision of Hon'ble Supreme Court rendered in CIT ....