GAJRA GLASSFIBRE PRIVATE LIMITED,MUMBAI vs. MUM-W-(101)(1), MUMBAI

ITA 1235/MUM/2026Status: DisposedITAT Mumbai20 May 2026AY 2013-1411 pages
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What were the facts?

The assessee filed TDS statements belatedly for periods prior to June 1, 2015. The Income Tax Department levied late fees under Section 234E of the Act, which was upheld by the CIT(A). The assessee appealed this decision.

What did the Tribunal hold?

The Tribunal held that the amendment to Section 200A of the Act, which enabled the levy of fees under Section 234E, was prospective and not applicable to TDS periods prior to June 1, 2015. Therefore, the levy of late fees was not sustainable for those periods.

What were the issues?

Whether late fees under Section 234E can be levied for TDS statements pertaining to periods prior to the effective date of the amendment to Section 200A, which enabled such levies.

Which sections of the Income-tax Act were involved?

Section 234E,Section 200A,Section 154,Section 206CB,Section 220

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, G BENCH, MUMBAI

Heard together (2 matters)

ITA No. 1236/MUM/2026
ITA No. 1238/MUM/2026

Read from the judgment's own cause title. This page is filed under one of them.

Per Rahul Chaudhary, Judicial Member:

1.

This is the batch of four appeals preferred by the same assessee. Since all the appeals involved identical issues the same were taken up together and are being disposed off by way of common order. There is the delay of 35 days in each of the appeal. The Assessee has filed application seeking condonation of delay.

The order continues below.

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