INFODYNAMIC INTEGRATION TECHNOLOGIES,PUNE vs. INCOME TAX OFFICER (TDS-2), PUNE

ITA 873/PUN/2026Status: DisposedITAT Pune16 September 2026AY 2013-146 pages
AI SummaryPartly Allowed

What were the facts?

The assessee filed a TDS return for Q4 of FY 2012-13 with a delay of 920 days. The TDS CPC processed the return and levied late fees under Section 234E, which was confirmed by the CIT(A).

What did the Tribunal hold?

The Tribunal held that late fees under Section 234E are leviable only from June 1, 2015, as the mechanism for levying such fees was introduced in Section 200A from that date. Therefore, fees for the period prior to June 1, 2015, should be deleted.

What were the issues?

Whether late fees under Section 234E are leviable for delays in filing TDS returns prior to June 1, 2015, when the processing mechanism under Section 200A was not yet in place.

Which sections of the Income-tax Act were involved?

Section 234E,Section 200A,Section 220(2),Section 154

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PUNE BENCH “A”, PUNE

Before: SHRI DR. DIPAK P. RIPOTE & SHRI VINAY BHAMORE

For Appellant: Shri C. V. Deshpande
For Respondent: Shri Sandip Pawar (Virtual)
Hearing: 24.06.2026Pronounced: 16.09.2026

PER VINAY BHAMORE, JM: This appeal filed by the assessee is directed against the order dated 06.02.2026 passed by Ld. Addl./JCIT(A)-1, Coimbatore [‘Ld. CIT(A)’] for the assessment year 2013-14. 2. The appellant has raised the following grounds of appeal :- “1. The learned CIT(A), National Faceless Appeal Centre (NFAC) erred in law and on facts in confirming levy of late fees u/s.234E of the ITA for delay in filing TDS Statement. The Ld. CIT (A),

2 National Faceless Appeal Centre (NFAC) ought to have appreciated that prior to 01-06-2015 the levy of fees u/s.234E is not permissible u/s.200A of the ITA.

2.

The Ld. CIT(A), National Faceless Appeal Centre (NFA

The order continues below.

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