2026 (4) TMI 1770

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....u/s.250 of the Income-tax Act, 1961 (in short 'the Act'). 2. Registry has pointed out that there is delay of 17 days in filing of the appeals before this Tribunal in the case of Sancheti Onions Pvt. Ltd. Assessee has submitted an Affidavit explaining the delay. On due consideration of the Affidavit, we find that 'reasonable cause' prevented the assessee to file the appeals within the stipulated time. We therefore adopting justice oriented approach and placing reliance on the judgments of Hon'ble Apex Court in the case of Collector, Land Acquisition, Anantnag & Anr. Vs. Mst. Katiji & Ors. reported in (1987) 2 SCC 107 and in the case of Inder Singh Vs. State of Madhya Pradesh judgment dated 21.03.2025 (2025 INSC 382) condone the delay of 1....

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....ons rendered by this Tribunal on this very issue. It shows that the late fee u/s.234E has been imposed for the delay in furnishing the statements for quarters, in the returns processed u/s.200A of the Act prior to 01.06.2015. By Finance Act 2015 Clause-(c) to section 200A(1) was introduced w.e.f. 01.06.2015 empowering the authority concerned to levy fee under section 234E of the Act while processing the TDS statement under section 200A of the Act. Therefore, prior to 01.06.2015 there was no specific provision under section 200A of the Act for levy of late filing fee under section 234E of the Act. Thus, taking note of the aforesaid factual position, different benches of the Tribunal consistently held that prior to 01.06.2015 provisions of se....