2025 (11) TMI 1999

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....al Faceless Appeal Centre (NFAC), New Delhi relevant to the assessment years 2013-14 [Q4, Q-3 & Q-2], 2014-15 [Q1, Q-3, Q-2 & Q-4], 2015-16 [Q-1, Q-2, Q-3 & Q-4] & 2016-17 [Q-1]. 2. We find that all the appeals are filed with a delay of one day. The assessee filed an affidavit for condonation of delay stating the reasons. Upon hearing both the parties and on examination of the said affidavit, we find the reasons stated by the assessee are bonafide, which really prevented in filing the appeal in time. Thus, the delay is condoned and admitted the appeal for adjudication. 3. Since, the facts are identical and issues are common, for the sake of convenience these appeals were heard together and are being disposed off, by this consolidated ....

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....aterial available on record. The solitary issue that needs to be resolved in the given facts and circumstances of the case is whether the Assessing Officer can levy late fee prescribed under section 234E of the Act, when the quarterly return filed by the tax deductor for the period prior to 01.06.2015, when the law has been amended by Finance Act enabling the Assessing Officer to compute late fee while processing TDS returns under section 200A of the Act. The provisions of section 234E of the Act has been inserted to the statute by Finance Act with effect from 01.07.2012 and provides levy of late fee for belated filing of quarterly return filed by the tax deductor. The Assessing Officer proceeded to levy of late fee under section 234E of th....