2026 (3) TMI 1704

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....0 of the Income Tax Act, 1961 (hereinafter called 'the Act'). The relevant Assessment Years are 2014-15, 2015-16 & 2016-17. 2. A common issue is raised in these appeals. Hence, they were heard together and are being disposed of by this consolidated order. The grounds raised are identical in all the appeals. The grounds raised read as follows:- "The order of Ld. CIT (A) is erroneous and bad in law. 2. The Ld. CIT (A) failed to understand that the S. 234E was prospective only w.r.t 15.6.2016 and not applicable to the appellant in this case. 3. The said TDS were deducted and paid to the government in time but couldn't file the returns in time due to unavoidable circumstances." 3. The Ld.AR submitted that assess....

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....enabling provision under the Act for the AO to levy / compute late fee u/s. 234E of the Act while processing TDS statements u/s. 200A of the Act. It was contended that the amendment to section 200A, which empowered the AO to levy such fee, came into effect only from 01.06.2015 and is prospective in nature. Therefore, according to the Ld. AR, the levy of late fee u/s. 234E of the Act for TDS statements pertaining to the period prior to 01.06.2015 is not sustainable and liable to be deleted. In support of the her contention, the Ld.AR relied on the judgment of the Hon'ble Madras High Court in the case of True Blue Voice India Pvt. Ltd. vs. CCIT reported in (2025) 472 ITR 480 and the decision of the Chennai Bench of the Tribunal in the case of....