2024 (3) TMI 1490

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.... PER DR. DIPAK P. RIPOTE, AM: These four appeals filed by the assessee are against the common order of Ld.Commissioner of Income Tax(Appeals) [NFAC], passed under section 250 of the Income Tax Act, 1961 all dated 21.11.2023. Since issue involved is same, all these appeals were heard together and decided by this consolidated order. We treat appeal in ITA No.128/PUN/2024 for A.Y.2013-14, as a lea....

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....f the Act Rs 21562/-. 4. The appellant craves, to consider each of the above grounds of appeal without prejudice to each other and craves leave to add, alter, delete or modify all or any of the above grounds of appeal." Findings & Analysis : 2. We have heard both the parties and perused the records. We are discussing ITA No.128/PUN/2024 hereonwards. 2.1 The issue involved in this case is w....

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....e same can be said as illegal and invalid. 24. ....................In view of the reasons recorded by us hereinabove, when the amendment made under Section 200A of the Act which has come into effect on 1.6.2015 is held to be having prospective effect, no computation of fee for the demand or the intimation for the fee under Section 234E could be made for the TDS deducted for the respective asses....

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....the assessee needs to be followed; as observed by the Hon'ble Supreme Court in the case of CIT Vs. Vegetable Products Limited [1973] 88 ITR 192 (SC). The decision of Hon'ble Karnataka High Court(supra) was followed by ITAT Pune Bench in the case of Medical Superintendent Rural Hospital, vs. DCIT, CPC(TDS) [2018] 100 taxmann.com 78. 2.5 In this case, Late Fee under section 234E has been levied for....