SHRAVANI INDUSTRIAL ENTERPRISES,PUNE vs. ADDL JCIT (A)-4 KOLKATA, KOLKATA

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ITA 938/PUN/2024Status: DisposedITAT Pune04 September 2024AY 2014-15Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI INTURI RAMA RAO (Accountant Member)2 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the statutory amendment to Section 200A(1) of the Income Tax Act, which allowed for the levy of late filing fees, had prospective effect from June 1, 2015. Since the assessment year in question was 2014-2015, the amendment was not applicable.

What were the facts?

The assessee filed an appeal for assessment year 2014-2015 against the imposition of late filing fee for delay in filing TDS statements. The appeal was proceeded ex-parte as the assessee did not appear.

What were the issues?

The primary issue was whether the late filing fee under Section 234E, levied under Section 200A(1), was applicable for the assessment year 2014-2015 given the prospective nature of the relevant amendment.

Which sections of the Income-tax Act were involved?

Section 200A(1),Section 234E

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PUNE “B” BENCH : PUNE

Before: SHRI SATBEER SINGH GODARA & SHRI INTURI RAMA RAO

Hearing: 03.09.2024Pronounced: 04.09.2024

Din and Order No.ITBA/APL/S/250/2023-24/1063619534(1), dated 29.03.2024, in proceedings u/s.200A(1) of the Income Tax Act, 1961 (in short “the Act”).

Case called twice. None appears at assessee’s behest. It is accordingly proceeded ex-parte.

2.

It emerges at the outset that the assessee’s identical sole substantive ground raised in the instant appeal seeks to reverse both the learned lower authorities action imposing

2 ITA.No.938/PUN./2024 sec.234E late filing fee for delay in filing of TDS statement(s) pertaining to the impugned assessment year. The first and foremost clinching aspect which emerges during the course of hearing is that the statutory amendment in sec.200A(1) clauses (c to f) substituting the earlier corresponding provisions, by Finance Act, 2015 w.e.f. 01.06.2015 carrying prospective effect and we are in assessment year 2014-2015.

We thus hardly see any merit in assessee’s identical sole substantive grievance. Rejected accordingly.

No other ground or argument has been pressed before us.

4.

This assessee’s appeal is allowed in above terms.

Order pronounced in the open Court on 04.09.2024.

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