(CWT v. Sharvan Kumar Swarup & Sons.

210 ITR 886Supreme Court of India1994#1525 most cited

What is (CWT v. Sharvan Kumar Swarup & Sons. authority for?

Substantive law is concerned with the ends of justice, while procedural law deals with the means to attain them. Procedural changes do not affect substantive rights.

74

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2007 to 2023.

Also referred to as

CWT v. Sharvan Kumar Swarup & Sons · substantive law · procedural law · administration of justice · litigation · tax law interpretation

Issues it is cited on

section 234e(1)section 200a(1)(c)section 254(2)section 200a(1)section 200(3)section 200asection 234esection 254(1)section 200tax deducted at sourcesection 20section 234

Judgments citing (CWT v. Sharvan Kumar Swarup & Sons.

Kerala Gramin Bank, Unnikulam Branch, Kozhikode vs. The ITO Ward TDS, Kozhikode

In the result, the appeals filed by the assessee are allowed

ITA 814/COCH/2022[2013-2014 (24Q, Q4)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

Kerala Gramin Bank, Unnikulam Branch, Kozhikode vs. The ITO Ward TDS, Kozhikode

In the result, the appeals filed by the assessee are allowed

ITA 813/COCH/2022[2013-2014(26Q,Q3)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

Kerala Gramin Bank, Unnikulam Branch, Kozhikode vs. The ITO Ward TDS, Kozhikode

In the result, the appeals filed by the assessee are allowed

ITA 812/COCH/2022[2013-2014(24Q, Q3)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

Kerala Gramin Bank, Unnikulam Branch, Kozhikode vs. The ITO Ward TDS, Kozhikode

In the result, the appeals filed by the assessee are allowed

ITA 811/COCH/2022[2013-2014(26Q, Q2)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

Kerala Gramin Bank, Unnikulam Branch, Kozhikode vs. The ITO Ward TDS, Kozhikode

In the result, the appeals filed by the assessee are allowed

ITA 810/COCH/2022[2013-2014(24Q,Q2)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

Kerala Gramin Bank, Ottappalam Branch, Palakkad vs. The ITO Ward TDS, Palakkad

In the result, the appeals filed by the assessee are allowed

ITA 809/COCH/2022[2013-2014(26Q,Q3)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

Kerala Gramin Bank, Ottappalam Branch, Palakkad vs. The ITO Ward TDS, Palakkad

In the result, the appeals filed by the assessee are allowed

ITA 808/COCH/2022[2013-2014(26Q,Q2)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

Kerala Gramin Bank, Ottappalam Branch, Palakkad vs. The ITO Ward TDS, Palakkad

In the result, the appeals filed by the assessee are allowed

ITA 807/COCH/2022[2013-2014(24Q,Q2)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

Kerala Gramin Bank, Omasseri Branch, Kozhikode vs. The ITO Ward TDS, Kozhikode

In the result, the appeals filed by the assessee are allowed

ITA 806/COCH/2022[2013-2014 (26Q, Q4)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

Kerala Gramin Bank, Omasseri Branch, Kozhikode vs. The ITO Ward TDS, Kozhikode

In the result, the appeals filed by the assessee are allowed

ITA 805/COCH/2022[2013-2014 (24Q, Q4)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

Kerala Gramin Bank, Omasseri Branch, Kozhikode vs. The ITO Ward TDS, Kozhikode

In the result, the appeals filed by the assessee are allowed

ITA 804/COCH/2022[2013-2014(26Q,Q2)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

Kerala Gramin Bank, Omasseri Branch, Kozhikode vs. The ITO Ward TDS, Kozhikode

In the result, the appeals filed by the assessee are allowed

ITA 803/COCH/2022[2013-2014(24Q,Q2)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

Kerala Gramin Bank, Onchiyam Branch, Kozhikode vs. The ITO Ward TDS, Kozhikode

In the result, the appeals filed by the assessee are allowed

ITA 802/COCH/2022[2013-2014(26Q,Q4)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

Kerala Gramin Bank, Onchiyam Branch, Kozhikode vs. The ITO Ward TDS, Kozhikode

In the result, the appeals filed by the assessee are allowed

ITA 801/COCH/2022[2013-2014(24Q,Q4)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

Kerala Gramin Bank, Onchiyam Branch, Kozhikode vs. The ITO Ward TDS, Kozhikode

In the result, the appeals filed by the assessee are allowed

ITA 800/COCH/2022[2013-2014 (26Q,Q3)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

Kerala Gramin Bank, Onchiyam Branch, Kozhikode vs. The ITO Ward TDS, Kozhikode

In the result, the appeals filed by the assessee are allowed

ITA 799/COCH/2022[2013-2014(24Q, Q3)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

Kerala Gramin Bank, Onchiyam Branch, Kozhikode vs. The ITO Ward TDS, Kozhikode

In the result, the appeals filed by the assessee are allowed

ITA 798/COCH/2022[2013-2014(26Q, Q2)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

Kerala Gramin Bank, Onchiyam Branch, Kozhikode vs. The ITO Ward TDS, Kozhikode

In the result, the appeals filed by the assessee are allowed

ITA 797/COCH/2022[2013-2014(24Q,Q2)]Status: DisposedITAT Cochin03 Mar 2023

Bench: Shri Sanjay Arora, Am & Shri Sandeep Gosain, Jm

For Appellant: Written Submissions (through S/Sh. Pratik Sadrani, HardikFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200Section 200(3)Section 200ASection 200A(1)Section 234ESection 234E(1)

…s. 200A(1) could thus validly be made qua fee u/s. 234E w.e.f. 01/6/2015. It is 3 | P a g e ITA No.797/Coch/2022 & Ors. Kerala Gramin Bank, Onchiyam Branch & Ors. trite law that there is no vested right in procedure (CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC)), which would therefore apply to pending matters, i.e., outstanding as on the date of amendment, even if it relates to a period prior thereto. It is trite law that the statute is to be read as a whole and, further, in interpreting the (machinery) provision, the rule is that a construction which makes the machinery workable should be preferre…

Madhyanchal Gramin Bank, Tendukheda Branch., Sagar vs. ITO(TDS)-1, Jabalpur

In the result, the assessee‟s appeals are dismissed

ITA 77/JAB/2022[2014-15]Status: DisposedITAT Jabalpur13 Sept 2022AY 2014-15

Bench: Shri Sanjay Arora, Hon‟Ble & Shri Manomohan Das, Hon'Ble

…be applicable w.e.f. that date, i.e., irrespective of the period to which the statement being processed thereunder may relate. Though the law in the matter is well-settled, one may toward this refer to the decision in CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC). In fact, even the levy is not retroactive, and is applicable only qua statements obliged to be filed on or after 01/7/2012. Further, for each case, the fees, though worked out (refer Note 1(c) of the Intimation) with reference to the due date of filing the statement for Qtr-II of f.y. 2012-13, i.e., 15/10/2012, the amount levied, being Rs.…

Madhyanchal Gramin Bank, Mandi Road Nowgong Branch., Sagar vs. ITO(TDS)-1, Jabalpur

In the result, the assessee‟s appeals are dismissed

ITA 76/JAB/2022[2013-14]Status: DisposedITAT Jabalpur13 Sept 2022AY 2013-14

Bench: Shri Sanjay Arora, Hon‟Ble & Shri Manomohan Das, Hon'Ble

…be applicable w.e.f. that date, i.e., irrespective of the period to which the statement being processed thereunder may relate. Though the law in the matter is well-settled, one may toward this refer to the decision in CWT v. Sharvan Kumar Swarup & Sons [1994] 210 ITR 886 (SC). In fact, even the levy is not retroactive, and is applicable only qua statements obliged to be filed on or after 01/7/2012. Further, for each case, the fees, though worked out (refer Note 1(c) of the Intimation) with reference to the due date of filing the statement for Qtr-II of f.y. 2012-13, i.e., 15/10/2012, the amount levied, being Rs.…