Assessing Officer Cannot Levy Section 234E Fees Before June 1, 2015 Amendment, ITAT Rules

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....The ITAT held that the Assessing Officer lacked authority to levy fees under section 234E by adjusting statements processed under section 200A prior to the amendment effective from 1.6.2015, as the enabling provisions were introduced only by the Finance Act 2015. Consequently, the levy of late fees under section 234E before this date was impermissible. The CIT(A)'s deletion of the fee levy was upheld, and the revenue's appeals were dismissed, affirming that no fee could be charged either by a separate order or during statement processing under section 200A before the statutory amendment.....