Conceria International (P.) Ltd. v. ITO

464 ITR 92High Court2024#4696 most cited

What is Conceria International (P.) Ltd. v. ITO authority for?

Section 234E, which provides for late fees for delayed filing of TDS statements, is a substantive provision and its levy is not dependent on Section 200A(1)(c). Therefore, late fees can be levied even for periods prior to June 1, 2015, when Section 200A was amended to explicitly include fee computation.

25

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2025 to 2026.

Also referred to as

Conceria International Pvt Ltd v ITO · Section 234E · Section 200A · late fee · TDS return delay · prior to June 1 2015 · substantive provision · recovery mechanism

Sections most often in play

Section 234ESection 200ASection 156Section 220(2)Section 119Section 143(1A)Section 201(1)Section 201(1A)

Issues it is cited on

section 115wasection 234e(1)section 143(1a)section 285section 117section 139(9)tax collected at sourcesection 200a(1)(c)interest under section 201(1a)section 120section 200a(1)section 206c

Judgments citing Conceria International (P.) Ltd. v. ITO

A2Z Waste Management (Fatehpur) Limited vs. Deputy/Assistant Commissioner of Income Tax (TDS)

Appeal is allowed

ITA 3302/DEL/2025[2014-15]Status: DisposedITAT Delhi14 Jan 2026AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Amitabh Shuklaassessment Year: 2015-16 With Assessment Year: 2013-14 With Assessment Year: 2013-14 With Assessment Year: 2014-15 With Assessment Year: 2014-15 A2Z Waste Management Vs. Deputy/Acit (Tds), (Fatehpur) Limited, Gurgaon, Haryana O-116, 1St Floor, Dlf Shopping Mall, Arjun Marg, Dlf City Phase 1, Dlf Qe, S.O. Gurgaon, Haryana Pan: Rtkao6550F (Appellant) (Respondent)

Section 200ASection 234E

…he case and in law, the Ld. CIT(A) has erred in dismissing the appeal. 3. Learned departmental representative vehemently argues that in light of the CIT(A)’s detailed discussion placing reliance upon the case law Conceria International Pvt. Ltd. v. ITO (2024) 464 ITR 92 (Mad.) that both the lower authorities herein have rightly levied section 234E late filing fee in the assessee’s/deductor’s cases. And that the impugned statutory provision has already been held applicable in all preceding period before 01.06.2015 as well in their lordships’ decision. 4. We have given our thoughtful consideration to the assessee’s…

A2Z Waste Management (Fatehpur) Limited vs. Deputy/Assistant Commissioner of Income Tax (TDS)

Appeal is allowed

ITA 3301/DEL/2025[2014-15]Status: DisposedITAT Delhi14 Jan 2026AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Amitabh Shuklaassessment Year: 2015-16 With Assessment Year: 2013-14 With Assessment Year: 2013-14 With Assessment Year: 2014-15 With Assessment Year: 2014-15 A2Z Waste Management Vs. Deputy/Acit (Tds), (Fatehpur) Limited, Gurgaon, Haryana O-116, 1St Floor, Dlf Shopping Mall, Arjun Marg, Dlf City Phase 1, Dlf Qe, S.O. Gurgaon, Haryana Pan: Rtkao6550F (Appellant) (Respondent)

Section 200ASection 234E

…he case and in law, the Ld. CIT(A) has erred in dismissing the appeal. 3. Learned departmental representative vehemently argues that in light of the CIT(A)’s detailed discussion placing reliance upon the case law Conceria International Pvt. Ltd. v. ITO (2024) 464 ITR 92 (Mad.) that both the lower authorities herein have rightly levied section 234E late filing fee in the assessee’s/deductor’s cases. And that the impugned statutory provision has already been held applicable in all preceding period before 01.06.2015 as well in their lordships’ decision. 4. We have given our thoughtful consideration to the assessee’s…

A2Z Waste Management (Fatehpur) Limited vs. Deputy/Assistant Commissioner of Income Tax (TDS)

Appeal is allowed

ITA 3300/DEL/2025[2013-14]Status: DisposedITAT Delhi14 Jan 2026AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri Amitabh Shuklaassessment Year: 2015-16 With Assessment Year: 2013-14 With Assessment Year: 2013-14 With Assessment Year: 2014-15 With Assessment Year: 2014-15 A2Z Waste Management Vs. Deputy/Acit (Tds), (Fatehpur) Limited, Gurgaon, Haryana O-116, 1St Floor, Dlf Shopping Mall, Arjun Marg, Dlf City Phase 1, Dlf Qe, S.O. Gurgaon, Haryana Pan: Rtkao6550F (Appellant) (Respondent)

Section 200ASection 234E

…he case and in law, the Ld. CIT(A) has erred in dismissing the appeal. 3. Learned departmental representative vehemently argues that in light of the CIT(A)’s detailed discussion placing reliance upon the case law Conceria International Pvt. Ltd. v. ITO (2024) 464 ITR 92 (Mad.) that both the lower authorities herein have rightly levied section 234E late filing fee in the assessee’s/deductor’s cases. And that the impugned statutory provision has already been held applicable in all preceding period before 01.06.2015 as well in their lordships’ decision. 4. We have given our thoughtful consideration to the assessee’s…

A2Z Waste Management (Fatehpur) Limited vs. Deputy/Assistant Commissioner of Income Tax (TDS)

Appeal is allowed

ITA 3299/DEL/2025[2013-14]Status: DisposedITAT Delhi14 Jan 2026AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri Amitabh Shuklaassessment Year: 2015-16 With Assessment Year: 2013-14 With Assessment Year: 2013-14 With Assessment Year: 2014-15 With Assessment Year: 2014-15 A2Z Waste Management Vs. Deputy/Acit (Tds), (Fatehpur) Limited, Gurgaon, Haryana O-116, 1St Floor, Dlf Shopping Mall, Arjun Marg, Dlf City Phase 1, Dlf Qe, S.O. Gurgaon, Haryana Pan: Rtkao6550F (Appellant) (Respondent)

Section 200ASection 234E

…he case and in law, the Ld. CIT(A) has erred in dismissing the appeal. 3. Learned departmental representative vehemently argues that in light of the CIT(A)’s detailed discussion placing reliance upon the case law Conceria International Pvt. Ltd. v. ITO (2024) 464 ITR 92 (Mad.) that both the lower authorities herein have rightly levied section 234E late filing fee in the assessee’s/deductor’s cases. And that the impugned statutory provision has already been held applicable in all preceding period before 01.06.2015 as well in their lordships’ decision. 4. We have given our thoughtful consideration to the assessee’s…

A2Z Waste Management (Fatehpur) Limited, Gurgaon vs. Deputy/Assistant Commissioner of Income Tax (TDS), Ghaziabad

Appeal is allowed

ITA 3287/DEL/2025[2015-16]Status: DisposedITAT Delhi14 Jan 2026AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Amitabh Shuklaassessment Year: 2015-16 With Assessment Year: 2013-14 With Assessment Year: 2013-14 With Assessment Year: 2014-15 With Assessment Year: 2014-15 A2Z Waste Management Vs. Deputy/Acit (Tds), (Fatehpur) Limited, Gurgaon, Haryana O-116, 1St Floor, Dlf Shopping Mall, Arjun Marg, Dlf City Phase 1, Dlf Qe, S.O. Gurgaon, Haryana Pan: Rtkao6550F (Appellant) (Respondent)

Section 200ASection 234E

…he case and in law, the Ld. CIT(A) has erred in dismissing the appeal. 3. Learned departmental representative vehemently argues that in light of the CIT(A)’s detailed discussion placing reliance upon the case law Conceria International Pvt. Ltd. v. ITO (2024) 464 ITR 92 (Mad.) that both the lower authorities herein have rightly levied section 234E late filing fee in the assessee’s/deductor’s cases. And that the impugned statutory provision has already been held applicable in all preceding period before 01.06.2015 as well in their lordships’ decision. 4. We have given our thoughtful consideration to the assessee’s…

Chate Tutorials Pvt Ltd, Aurangabad vs. Assistant Commissioner of Income Tax, TDS Circle, Nashik

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

ITA 480/PUN/2024[2022-23]Status: DisposedITAT Pune25 Jun 2025AY 2022-23

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

For Appellant: Shri Aditya NavandarFor Respondent: Shri Ramnath P. Murkunde
Section 200ASection 234E

…al tax. Accordingly, when one equates the fee u/s 234E as an additional tax, there is no infirmity in the CPC processing the TDS statements and computing the late fee/additional tax. 2.8 In Conceria International (P.) Ltd. Vs ITO [2023] 157 taxmann.com 335 / 464 ITR 92 (Madras), the Hon’ble Madras High Court has held that the challenge to order imposing levy of late fee prior to 1-6-2015 was to be rejected as section 234E which provides for late fee is substantive provision and levy is not dependent on section 200A(1)(c) which only prescribes a recovery mechanism. The Hon’ble Madras High Court has held that, a…

Chate Tutorials Pvt. Ltd., Aurangabad vs. Ld. Assistant Commissioner of Income Tax, TDS Circle, Nashik

In the result, both the bunch of appeals filed by the

ITA 479/PUN/2024[2021-22]Status: DisposedITAT Pune25 Jun 2025AY 2021-22
For Appellant: Shri Aditya NavandarFor Respondent: Shri Ramnath P. Murkunde
Section 200ASection 234E

…nal tax. Accordingly, when one equates the fee u/s 234E as an additional tax, there is no infirmity in the CPC processing the TDS statements and computing the late fee/additional tax. 2.8 In Conceria International (P.) Ltd. Vs ITO [2023] 157 taxmann.com 335 / 464 ITR 92 (Madras), the Hon'ble Madras High Court has held that the challenge to order imposing levy of late fee prior to 1-6-2015 was to be rejected as section 234E which provides for late fee is substantive provision and levy is not dependent on section 200A(1)(c) which only prescribes a recovery mechanism. The Hon'ble Madras High Court has held that, a r…

Chate Tutorials Pvt. Ltd., Aurangabad vs. Ld. Assistant Commissioner of Income Tax, TDS Circle, Nashik

In the result, both the bunch of appeals filed by the

ITA 478/PUN/2024[2020-21]Status: DisposedITAT Pune25 Jun 2025AY 2020-21
Section 200ASection 234E

…nal tax. Accordingly, when one equates the fee u/s 234E as an additional tax, there is no infirmity in the CPC processing the TDS statements and computing the late fee/additional tax. 2.8 In Conceria International (P.) Ltd. Vs ITO [2023] 157 taxmann.com 335 / 464 ITR 92 (Madras), the Hon'ble Madras High Court has held that the challenge to order imposing levy of late fee prior to 1-6-2015 was to be rejected as section 234E which provides for late fee is substantive provision and levy is not dependent on section 200A(1)(c) which only prescribes a recovery mechanism. The Hon'ble Madras High Court has held that, a r…

Chate Tutorials Pvt. Ltd. Aurangabad, Aurangabad vs. Ld. Assistant Commissioner of Income Tax, TDS Circle, Nashik

In the result, both the bunch of appeals filed by the

ITA 477/PUN/2024[2018-19]Status: DisposedITAT Pune25 Jun 2025AY 2018-19
For Appellant: Shri Aditya NavandarFor Respondent: Shri Ramnath P. Murkunde
Section 200ASection 234E

…nal tax. Accordingly, when one equates the fee u/s 234E as an additional tax, there is no infirmity in the CPC processing the TDS statements and computing the late fee/additional tax. 2.8 In Conceria International (P.) Ltd. Vs ITO [2023] 157 taxmann.com 335 / 464 ITR 92 (Madras), the Hon'ble Madras High Court has held that the challenge to order imposing levy of late fee prior to 1-6-2015 was to be rejected as section 234E which provides for late fee is substantive provision and levy is not dependent on section 200A(1)(c) which only prescribes a recovery mechanism. The Hon'ble Madras High Court has held that, a r…

Chate Tutorials Pvt. Ltd., Aurangabad vs. Ld. Assistant Commissioner of Income Tax, TDS Circle, Nashik

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

ITA 476/PUN/2024[2017-18]Status: DisposedITAT Pune25 Jun 2025AY 2017-18

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

For Appellant: Shri Aditya NavandarFor Respondent: Shri Ramnath P. Murkunde
Section 200ASection 234E

…al tax. Accordingly, when one equates the fee u/s 234E as an additional tax, there is no infirmity in the CPC processing the TDS statements and computing the late fee/additional tax. 2.8 In Conceria International (P.) Ltd. Vs ITO [2023] 157 taxmann.com 335 / 464 ITR 92 (Madras), the Hon’ble Madras High Court has held that the challenge to order imposing levy of late fee prior to 1-6-2015 was to be rejected as section 234E which provides for late fee is substantive provision and levy is not dependent on section 200A(1)(c) which only prescribes a recovery mechanism. The Hon’ble Madras High Court has held that, a…

Shree Bhaskaracharya Pratishthan, Chh Sambhajinagar vs. Ld. Deputy Commissioner of Income Tax, CPC-TDS

In the result, both the bunch of appeals filed by the

ITA 2377/PUN/2024[2023-24]Status: DisposedITAT Pune25 Jun 2025AY 2023-24
Section 200ASection 234E

…nal tax. Accordingly, when one equates the fee u/s 234E as an additional tax, there is no infirmity in the CPC processing the TDS statements and computing the late fee/additional tax. 2.8 In Conceria International (P.) Ltd. Vs ITO [2023] 157 taxmann.com 335 / 464 ITR 92 (Madras), the Hon'ble Madras High Court has held that the challenge to order imposing levy of late fee prior to 1-6-2015 was to be rejected as section 234E which provides for late fee is substantive provision and levy is not dependent on section 200A(1)(c) which only prescribes a recovery mechanism. The Hon'ble Madras High Court has held that, a r…

Shri Bhaskaracharya Pratishthan, Chh Sambhajinagar vs. Ld. Deputy Commissioner of Income Tax, CPC-TDS

In the result, both the bunch of appeals filed by the

ITA 2368/PUN/2024[2024-2025]Status: DisposedITAT Pune25 Jun 2025AY 2024-2025
For Appellant: Shri Aditya NavandarFor Respondent: Shri Ramnath P. Murkunde
Section 200ASection 234E

…nal tax. Accordingly, when one equates the fee u/s 234E as an additional tax, there is no infirmity in the CPC processing the TDS statements and computing the late fee/additional tax. 2.8 In Conceria International (P.) Ltd. Vs ITO [2023] 157 taxmann.com 335 / 464 ITR 92 (Madras), the Hon'ble Madras High Court has held that the challenge to order imposing levy of late fee prior to 1-6-2015 was to be rejected as section 234E which provides for late fee is substantive provision and levy is not dependent on section 200A(1)(c) which only prescribes a recovery mechanism. The Hon'ble Madras High Court has held that, a r…

Shree Bhaskaracharya Pratishthan, Chh Sambhajinagar vs. Ld. Deputy Commissioner of Income Tax, CPC-TDS

In the result, both the bunch of appeals filed by the

ITA 2367/PUN/2024[2023-24]Status: DisposedITAT Pune25 Jun 2025AY 2023-24
For Appellant: Shri Aditya NavandarFor Respondent: Shri Ramnath P. Murkunde
Section 200ASection 234E

…nal tax. Accordingly, when one equates the fee u/s 234E as an additional tax, there is no infirmity in the CPC processing the TDS statements and computing the late fee/additional tax. 2.8 In Conceria International (P.) Ltd. Vs ITO [2023] 157 taxmann.com 335 / 464 ITR 92 (Madras), the Hon'ble Madras High Court has held that the challenge to order imposing levy of late fee prior to 1-6-2015 was to be rejected as section 234E which provides for late fee is substantive provision and levy is not dependent on section 200A(1)(c) which only prescribes a recovery mechanism. The Hon'ble Madras High Court has held that, a r…

Shri Bhaskaracharya Pratishthan, Chh. Sambhajinagar vs. Ld. Deputy Commissioner of Income Tax, CPC-TDS

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

ITA 2366/PUN/2024[2022-23]Status: DisposedITAT Pune25 Jun 2025AY 2022-23

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

For Appellant: Shri Aditya NavandarFor Respondent: Shri Ramnath P. Murkunde
Section 200ASection 234E

…al tax. Accordingly, when one equates the fee u/s 234E as an additional tax, there is no infirmity in the CPC processing the TDS statements and computing the late fee/additional tax. 2.8 In Conceria International (P.) Ltd. Vs ITO [2023] 157 taxmann.com 335 / 464 ITR 92 (Madras), the Hon’ble Madras High Court has held that the challenge to order imposing levy of late fee prior to 1-6-2015 was to be rejected as section 234E which provides for late fee is substantive provision and levy is not dependent on section 200A(1)(c) which only prescribes a recovery mechanism. The Hon’ble Madras High Court has held that, a…

Shri Bhaskaracharya Pratishthan, Chh. Sambhajinagar vs. Ld. Deputy Commissioner of Income Tax, CPC-TDS

In the result, both the bunch of appeals filed by the

ITA 2365/PUN/2024[2022-23]Status: DisposedITAT Pune25 Jun 2025AY 2022-23
For Appellant: Shri Aditya NavandarFor Respondent: Shri Ramnath P. Murkunde
Section 200ASection 234E

…nal tax. Accordingly, when one equates the fee u/s 234E as an additional tax, there is no infirmity in the CPC processing the TDS statements and computing the late fee/additional tax. 2.8 In Conceria International (P.) Ltd. Vs ITO [2023] 157 taxmann.com 335 / 464 ITR 92 (Madras), the Hon'ble Madras High Court has held that the challenge to order imposing levy of late fee prior to 1-6-2015 was to be rejected as section 234E which provides for late fee is substantive provision and levy is not dependent on section 200A(1)(c) which only prescribes a recovery mechanism. The Hon'ble Madras High Court has held that, a r…

Shree Bhaskaracharya Pratishthan, Chh Sambhajinagar vs. Ld. Deputy Commissioner of Income Tax, Ghaziabad

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

ITA 2364/PUN/2024[2021-22]Status: DisposedITAT Pune25 Jun 2025AY 2021-22

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

For Appellant: Shri Aditya NavandarFor Respondent: Shri Ramnath P. Murkunde
Section 200ASection 234E

…al tax. Accordingly, when one equates the fee u/s 234E as an additional tax, there is no infirmity in the CPC processing the TDS statements and computing the late fee/additional tax. 2.8 In Conceria International (P.) Ltd. Vs ITO [2023] 157 taxmann.com 335 / 464 ITR 92 (Madras), the Hon’ble Madras High Court has held that the challenge to order imposing levy of late fee prior to 1-6-2015 was to be rejected as section 234E which provides for late fee is substantive provision and levy is not dependent on section 200A(1)(c) which only prescribes a recovery mechanism. The Hon’ble Madras High Court has held that, a…

Shree Bhaskaracharya Pratishthan, Chh Sambhajinagar vs. Ld. Deputy Commissioner of Income Tax, CPC-TDS

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

ITA 2362/PUN/2024[2023-24]Status: DisposedITAT Pune25 Jun 2025AY 2023-24

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

For Appellant: Shri Aditya NavandarFor Respondent: Shri Ramnath P. Murkunde
Section 200ASection 234E

…al tax. Accordingly, when one equates the fee u/s 234E as an additional tax, there is no infirmity in the CPC processing the TDS statements and computing the late fee/additional tax. 2.8 In Conceria International (P.) Ltd. Vs ITO [2023] 157 taxmann.com 335 / 464 ITR 92 (Madras), the Hon’ble Madras High Court has held that the challenge to order imposing levy of late fee prior to 1-6-2015 was to be rejected as section 234E which provides for late fee is substantive provision and levy is not dependent on section 200A(1)(c) which only prescribes a recovery mechanism. The Hon’ble Madras High Court has held that, a…

Shri Bhaskaracharya Pratishthan, Chh. Sambhajinagar vs. Ld. Deputy Commissioner of Income Tax, CPC-TDS

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

ITA 2361/PUN/2024[2021-22]Status: DisposedITAT Pune25 Jun 2025AY 2021-22

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

For Appellant: Shri Aditya NavandarFor Respondent: Shri Ramnath P. Murkunde
Section 200ASection 234E

…al tax. Accordingly, when one equates the fee u/s 234E as an additional tax, there is no infirmity in the CPC processing the TDS statements and computing the late fee/additional tax. 2.8 In Conceria International (P.) Ltd. Vs ITO [2023] 157 taxmann.com 335 / 464 ITR 92 (Madras), the Hon’ble Madras High Court has held that the challenge to order imposing levy of late fee prior to 1-6-2015 was to be rejected as section 234E which provides for late fee is substantive provision and levy is not dependent on section 200A(1)(c) which only prescribes a recovery mechanism. The Hon’ble Madras High Court has held that, a…

Shree Bhaskaracharya Pratishthan, Chh Sambhajinagar vs. Ld. Deputy Commissioner of Income Tax CPC TDS, Ghaziabad

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

ITA 2360/PUN/2024[2023-2024]Status: DisposedITAT Pune25 Jun 2025AY 2023-2024

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

For Appellant: Shri Aditya NavandarFor Respondent: Shri Ramnath P. Murkunde
Section 200ASection 234E

…al tax. Accordingly, when one equates the fee u/s 234E as an additional tax, there is no infirmity in the CPC processing the TDS statements and computing the late fee/additional tax. 2.8 In Conceria International (P.) Ltd. Vs ITO [2023] 157 taxmann.com 335 / 464 ITR 92 (Madras), the Hon’ble Madras High Court has held that the challenge to order imposing levy of late fee prior to 1-6-2015 was to be rejected as section 234E which provides for late fee is substantive provision and levy is not dependent on section 200A(1)(c) which only prescribes a recovery mechanism. The Hon’ble Madras High Court has held that, a…

Shree Bhaskaracharya Pratishthan, Chh Sambhajinagar vs. Ld. Deputy Commissioner of Income Tax, Ghaziabad

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

ITA 2359/PUN/2024[2020-21]Status: DisposedITAT Pune25 Jun 2025AY 2020-21

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

For Appellant: Shri Aditya NavandarFor Respondent: Shri Ramnath P. Murkunde
Section 200ASection 234E

…al tax. Accordingly, when one equates the fee u/s 234E as an additional tax, there is no infirmity in the CPC processing the TDS statements and computing the late fee/additional tax. 2.8 In Conceria International (P.) Ltd. Vs ITO [2023] 157 taxmann.com 335 / 464 ITR 92 (Madras), the Hon’ble Madras High Court has held that the challenge to order imposing levy of late fee prior to 1-6-2015 was to be rejected as section 234E which provides for late fee is substantive provision and levy is not dependent on section 200A(1)(c) which only prescribes a recovery mechanism. The Hon’ble Madras High Court has held that, a…