Olari Little Flower Kuries (P.) Ltd. v. UOI

440 ITR 26High Court2022#95 most cited

What is Olari Little Flower Kuries (P.) Ltd. v. UOI authority for?

The fee under Section 234E of the Income-tax Act cannot be levied for defaults in filing TDS statements committed prior to June 1, 2015, as the provision for its levy became effective only from that date.

614

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2022 to 2026.

Also referred to as

Olari Little Flower Kuries (P.) Ltd. · Section 234E · fee for late filing of TDS statements · applicability prior to June 1 · 2015 · retrospective effect of Section 234E · non-imposition of fee · defaults before 01.06.2015 · TDS fee commencement date · Section 200A · Kerala High Court

Also reported as

134 Taxmann.com 111

Sections most often in play

Section 200ASection 234ESection 250Section 154Section 220(2)Section 206CBSection 200A(1)(c)Section 234A

Issues it is cited on

section 234e(1)section 200a(1)(c)section 200a(1)section 234esection 200asection 200section 200(3)section 254(2)section 220(2)tax deducted at sourcesection 20section 234

Judgments citing Olari Little Flower Kuries (P.) Ltd. v. UOI

RAMESH CHANDANMAL GUNDECHA,AHMEDNAGAR vs. ITO WARD 1, AHMEDNAGAR, AHMEDNAGAR

In the result, the appeals of the respective assessee(s) are ALLOWED

ITA 401/PUN/2026[AY 2013-14 Q4-26Q]Status: DisposedITAT Pune17 Apr 2026

Bench: Dr.Manish Borad & Shri Pavan Kumar Gadale

For Appellant: Shri Sourabh PatilFor Respondent: Shri Ganesh B. Budruk
Section 154Section 200ASection 200A(1)Section 234ESection 250

…of the matter, Revenue authorities are empowered to impose such late fee u/s.234E only for the default committed after 01.06.2015 and not prior to that. The Hon’ble Kerala High Court in Olari Little Flower Kuries Pvt. Ltd. Vs. Union of India and others (2022) 440 ITR 26 (Kerala) has affirmed the non-imposition of fee for the period prior to 01.06.2015. Similar view has been taken in Jiji Varghese VS. ITO(TDS) & Ors. (2022) 443 ITR 267 (Ker) holding that no fee u/s.234E can be imposed for the periods of the respective A.Ys. prior to 1st June, 2015. Similar view was also taken by this Tribunal in the case of Dadasa…

VANDANA ABHAY TATED,NASHIK vs. ITO WARD 2(1), NASHIK, NASHIK

In the result, all the appeals of the assessee are ALLOWED

ITA 391/PUN/2026[2015-16 Q3-26Q]Status: DisposedITAT Pune17 Apr 2026

Bench: Dr.Manish Borad & Shri Pavan Kumar Gadale

For Appellant: Shri Piyush Premchand BafnaFor Respondent: Shri Ganesh B. Budruk
Section 154Section 200ASection 200A(1)Section 234ESection 250

…o impose such late fee u/s.234E only for the ITA Nos. 381 to 383/PUN/2026 Vandana Abhay Tated default committed after 01.06.2015 and not prior to that. The Hon’ble Kerala High Court in Olari Little Flower Kuries Pvt. Ltd. Vs. Union of India and others (2022) 440 ITR 26 (Kerala) has affirmed the non-imposition of fee for the period prior to 01.06.2015. Similar view has been taken in Jiji Varghese VS. ITO(TDS) & Ors. (2022) 443 ITR 267 (Ker) holding that no fee u/s.234E can be imposed for the periods of the respective A.Ys. prior to 1st June, 2015. Similar view was also taken by this Tribunal in the case of Dadasa…

VANDANA ABHAY TATED,NASHIK vs. ITO WARD 2(1), NASHIK, NASHIK

In the result, all the appeals of the assessee are ALLOWED

ITA 382/PUN/2026[2015-16 Q1-26Q]Status: DisposedITAT Pune17 Apr 2026

Bench: Dr.Manish Borad & Shri Pavan Kumar Gadale

For Appellant: Shri Piyush Premchand BafnaFor Respondent: Shri Ganesh B. Budruk
Section 154Section 200ASection 200A(1)Section 234ESection 250

…o impose such late fee u/s.234E only for the ITA Nos. 381 to 383/PUN/2026 Vandana Abhay Tated default committed after 01.06.2015 and not prior to that. The Hon’ble Kerala High Court in Olari Little Flower Kuries Pvt. Ltd. Vs. Union of India and others (2022) 440 ITR 26 (Kerala) has affirmed the non-imposition of fee for the period prior to 01.06.2015. Similar view has been taken in Jiji Varghese VS. ITO(TDS) & Ors. (2022) 443 ITR 267 (Ker) holding that no fee u/s.234E can be imposed for the periods of the respective A.Ys. prior to 1st June, 2015. Similar view was also taken by this Tribunal in the case of Dadasa…

VANDANA ABHAY TATED,NASHIK vs. ITO WARD 2(1), NASHIK, NASHIK

In the result, all the appeals of the assessee are ALLOWED

ITA 381/PUN/2026[2015-16 Q2-26Q]Status: DisposedITAT Pune17 Apr 2026

Bench: Dr.Manish Borad & Shri Pavan Kumar Gadale

For Appellant: Shri Piyush Premchand BafnaFor Respondent: Shri Ganesh B. Budruk
Section 154Section 200ASection 200A(1)Section 234ESection 250

…o impose such late fee u/s.234E only for the ITA Nos. 381 to 383/PUN/2026 Vandana Abhay Tated default committed after 01.06.2015 and not prior to that. The Hon’ble Kerala High Court in Olari Little Flower Kuries Pvt. Ltd. Vs. Union of India and others (2022) 440 ITR 26 (Kerala) has affirmed the non-imposition of fee for the period prior to 01.06.2015. Similar view has been taken in Jiji Varghese VS. ITO(TDS) & Ors. (2022) 443 ITR 267 (Ker) holding that no fee u/s.234E can be imposed for the periods of the respective A.Ys. prior to 1st June, 2015. Similar view was also taken by this Tribunal in the case of Dadasa…

VANDANA ABHAY TATED,NASHIK vs. ITO WARD 2(1), NASHIK, NASHIK

In the result, all the appeals of the assessee are ALLOWED

ITA 370/PUN/2026[2014-15 Q4-26Q]Status: DisposedITAT Pune17 Apr 2026

Bench: Dr.Manish Borad & Shri Pavan Kumar Gadale

For Appellant: Shri Piyush Premchand BafnaFor Respondent: Shri Ganesh B. Budruk
Section 154Section 200ASection 200A(1)Section 234ESection 250

…o impose such late fee u/s.234E only for the ITA Nos. 381 to 383/PUN/2026 Vandana Abhay Tated default committed after 01.06.2015 and not prior to that. The Hon’ble Kerala High Court in Olari Little Flower Kuries Pvt. Ltd. Vs. Union of India and others (2022) 440 ITR 26 (Kerala) has affirmed the non-imposition of fee for the period prior to 01.06.2015. Similar view has been taken in Jiji Varghese VS. ITO(TDS) & Ors. (2022) 443 ITR 267 (Ker) holding that no fee u/s.234E can be imposed for the periods of the respective A.Ys. prior to 1st June, 2015. Similar view was also taken by this Tribunal in the case of Dadasa…

VANDANA ABHAY TATED,NASHIK vs. ITO WARD 2(1), NASHIK, NASHIK

In the result, all the appeals of the assessee are ALLOWED

ITA 369/PUN/2026[2014-15 Q2-26Q]Status: DisposedITAT Pune17 Apr 2026

Bench: Dr.Manish Borad & Shri Pavan Kumar Gadale

For Appellant: Shri Piyush Premchand BafnaFor Respondent: Shri Ganesh B. Budruk
Section 154Section 200ASection 200A(1)Section 234ESection 250

…o impose such late fee u/s.234E only for the ITA Nos. 381 to 383/PUN/2026 Vandana Abhay Tated default committed after 01.06.2015 and not prior to that. The Hon’ble Kerala High Court in Olari Little Flower Kuries Pvt. Ltd. Vs. Union of India and others (2022) 440 ITR 26 (Kerala) has affirmed the non-imposition of fee for the period prior to 01.06.2015. Similar view has been taken in Jiji Varghese VS. ITO(TDS) & Ors. (2022) 443 ITR 267 (Ker) holding that no fee u/s.234E can be imposed for the periods of the respective A.Ys. prior to 1st June, 2015. Similar view was also taken by this Tribunal in the case of Dadasa…

MRS. VANDANA ABHAY TATED,NASHIK vs. ITO WARD 2(1), NASHIK, NASHIK

In the result, all the appeals of the assessee are ALLOWED

ITA 367/PUN/2026[2013-14 Q2- 26Q]Status: DisposedITAT Pune17 Apr 2026

Bench: Dr.Manish Borad & Shri Pavan Kumar Gadale

For Appellant: Shri Piyush Premchand BafnaFor Respondent: Shri Ganesh B. Budruk
Section 154Section 200ASection 200A(1)Section 234ESection 250

…o impose such late fee u/s.234E only for the ITA Nos. 381 to 383/PUN/2026 Vandana Abhay Tated default committed after 01.06.2015 and not prior to that. The Hon’ble Kerala High Court in Olari Little Flower Kuries Pvt. Ltd. Vs. Union of India and others (2022) 440 ITR 26 (Kerala) has affirmed the non-imposition of fee for the period prior to 01.06.2015. Similar view has been taken in Jiji Varghese VS. ITO(TDS) & Ors. (2022) 443 ITR 267 (Ker) holding that no fee u/s.234E can be imposed for the periods of the respective A.Ys. prior to 1st June, 2015. Similar view was also taken by this Tribunal in the case of Dadasa…

VANDANA ABHAY TATED,NASHIK vs. ITO WARD 2(1), NASHIK, NASHIK

In the result, all the appeals of the assessee are ALLOWED

ITA 366/PUN/2026[2014-15 Q3-26Q]Status: DisposedITAT Pune17 Apr 2026

Bench: Dr.Manish Borad & Shri Pavan Kumar Gadale

For Appellant: Shri Piyush Premchand BafnaFor Respondent: Shri Ganesh B. Budruk
Section 154Section 200ASection 200A(1)Section 234ESection 250

…o impose such late fee u/s.234E only for the ITA Nos. 381 to 383/PUN/2026 Vandana Abhay Tated default committed after 01.06.2015 and not prior to that. The Hon’ble Kerala High Court in Olari Little Flower Kuries Pvt. Ltd. Vs. Union of India and others (2022) 440 ITR 26 (Kerala) has affirmed the non-imposition of fee for the period prior to 01.06.2015. Similar view has been taken in Jiji Varghese VS. ITO(TDS) & Ors. (2022) 443 ITR 267 (Ker) holding that no fee u/s.234E can be imposed for the periods of the respective A.Ys. prior to 1st June, 2015. Similar view was also taken by this Tribunal in the case of Dadasa…

VANDANA ABHAY TATED,NASHIK vs. ITO WARD 2(1), NASHIK, NASHIK

In the result, all the appeals of the assessee are ALLOWED

ITA 365/PUN/2026[2013-14 Q3- 26Q]Status: DisposedITAT Pune17 Apr 2026

Bench: Dr.Manish Borad & Shri Pavan Kumar Gadale

For Appellant: Shri Piyush Premchand BafnaFor Respondent: Shri Ganesh B. Budruk
Section 154Section 200ASection 200A(1)Section 234ESection 250

…o impose such late fee u/s.234E only for the ITA Nos. 381 to 383/PUN/2026 Vandana Abhay Tated default committed after 01.06.2015 and not prior to that. The Hon’ble Kerala High Court in Olari Little Flower Kuries Pvt. Ltd. Vs. Union of India and others (2022) 440 ITR 26 (Kerala) has affirmed the non-imposition of fee for the period prior to 01.06.2015. Similar view has been taken in Jiji Varghese VS. ITO(TDS) & Ors. (2022) 443 ITR 267 (Ker) holding that no fee u/s.234E can be imposed for the periods of the respective A.Ys. prior to 1st June, 2015. Similar view was also taken by this Tribunal in the case of Dadasa…

SANCHETI ONIONS PVT LTD,PUNE vs. WARD 10(1), PUNE, PUNE

In the result, the appeals of the respective assessee(s) are ALLOWED

ITA 2689/PUN/2025[2014-15]Status: DisposedITAT Pune17 Apr 2026AY 2014-15

Bench: Dr.Manish Borad & Shri Pavan Kumar Gadale

For Appellant: Shri Sourabh PatilFor Respondent: Shri Ganesh B. Budruk
Section 154Section 200ASection 200A(1)Section 234ESection 250

…of the matter, Revenue authorities are empowered to impose such late fee u/s.234E only for the default committed after 01.06.2015 and not prior to that. The Hon’ble Kerala High Court in Olari Little Flower Kuries Pvt. Ltd. Vs. Union of India and others (2022) 440 ITR 26 (Kerala) has affirmed the non-imposition of fee for the period prior to 01.06.2015. Similar view has been taken in Jiji Varghese VS. ITO(TDS) & Ors. (2022) 443 ITR 267 (Ker) holding that no fee u/s.234E can be imposed for the periods of the respective A.Ys. prior to 1st June, 2015. Similar view was also taken by this Tribunal in the case of Dadasa…

SANCHETI ONIONS PVT LTD,PUNE vs. WARD 10 (1) PUNE, PUNE

In the result, the appeals of the respective assessee(s) are ALLOWED

ITA 2688/PUN/2025[2014-15]Status: DisposedITAT Pune17 Apr 2026AY 2014-15

Bench: Dr.Manish Borad & Shri Pavan Kumar Gadale

For Appellant: Shri Sourabh PatilFor Respondent: Shri Ganesh B. Budruk
Section 154Section 200ASection 200A(1)Section 234ESection 250

…of the matter, Revenue authorities are empowered to impose such late fee u/s.234E only for the default committed after 01.06.2015 and not prior to that. The Hon’ble Kerala High Court in Olari Little Flower Kuries Pvt. Ltd. Vs. Union of India and others (2022) 440 ITR 26 (Kerala) has affirmed the non-imposition of fee for the period prior to 01.06.2015. Similar view has been taken in Jiji Varghese VS. ITO(TDS) & Ors. (2022) 443 ITR 267 (Ker) holding that no fee u/s.234E can be imposed for the periods of the respective A.Ys. prior to 1st June, 2015. Similar view was also taken by this Tribunal in the case of Dadasa…

VANDANA ABHAY TATED,NASHIK vs. ITO WARD 2(1), NASHIK, NASHIK

In the result, all the appeals of the assessee are ALLOWED

ITA 383/PUN/2026[2014-15 Q1- 26Q]Status: DisposedITAT Pune17 Apr 2026

Bench: Dr.Manish Borad & Shri Pavan Kumar Gadale

For Appellant: Shri Piyush Premchand BafnaFor Respondent: Shri Ganesh B. Budruk
Section 154Section 200ASection 200A(1)Section 234ESection 250

…o impose such late fee u/s.234E only for the ITA Nos. 381 to 383/PUN/2026 Vandana Abhay Tated default committed after 01.06.2015 and not prior to that. The Hon’ble Kerala High Court in Olari Little Flower Kuries Pvt. Ltd. Vs. Union of India and others (2022) 440 ITR 26 (Kerala) has affirmed the non-imposition of fee for the period prior to 01.06.2015. Similar view has been taken in Jiji Varghese VS. ITO(TDS) & Ors. (2022) 443 ITR 267 (Ker) holding that no fee u/s.234E can be imposed for the periods of the respective A.Ys. prior to 1st June, 2015. Similar view was also taken by this Tribunal in the case of Dadasa…

VANDANA ABHAY TATED,NASHIK vs. ITO WARD 2(1), NASHIK, NASHIK

In the result, all the appeals of the assessee are ALLOWED

ITA 368/PUN/2026[2013-14 Q4- 26Q]Status: DisposedITAT Pune17 Apr 2026

Bench: Dr.Manish Borad & Shri Pavan Kumar Gadale

For Appellant: Shri Piyush Premchand BafnaFor Respondent: Shri Ganesh B. Budruk
Section 154Section 200ASection 200A(1)Section 234ESection 250

…o impose such late fee u/s.234E only for the ITA Nos. 381 to 383/PUN/2026 Vandana Abhay Tated default committed after 01.06.2015 and not prior to that. The Hon’ble Kerala High Court in Olari Little Flower Kuries Pvt. Ltd. Vs. Union of India and others (2022) 440 ITR 26 (Kerala) has affirmed the non-imposition of fee for the period prior to 01.06.2015. Similar view has been taken in Jiji Varghese VS. ITO(TDS) & Ors. (2022) 443 ITR 267 (Ker) holding that no fee u/s.234E can be imposed for the periods of the respective A.Ys. prior to 1st June, 2015. Similar view was also taken by this Tribunal in the case of Dadasa…

NEW HIGH SCHOOL ,AURANGABAD vs. ACIT CENTRALIZED PROCESSING CELL -TDS, AURANGABAD

In the result, the appeal filed by the assessee in ITA

ITA 2641/PUN/2025[2014-15]Status: DisposedITAT Pune26 Mar 2026AY 2014-15

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.2638, 2640 & 2641/Pun/2025 िनधा"रण वष" / Assessment Year : 2014-15 New High School, Vs. Acit, Cpc-Tds, Tq. Jafrabad, At Post Warud, Ghaziabad. Jalna- 431206. Pan : Aabtm0727H Appellant Respondent Assessee By Shri Ashutosh Dhoot (Virtual) : Revenue By : Shri Rajesh Gawali Date Of Hearing : 09.03.2026 Date Of Pronouncement : 26.03.2026 आदेश / Order Per Vinay Bhamore, Jm: These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 10.09.2025 Passed By Ld. Addl./Jcit(A)-1, Coimbatore [‘Ld. Cit(A)’] For The Assessment Year 2014-15 Respectively. 2. Since Identical Facts & Common Issues Are Involved In All The Above Captioned Three Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 3. First, We Shall Take Up The Appeal Of The Assessee In Ita No.2638/Pun/2025 For Adjudication As The Lead Case.

For Respondent: Shri Rajesh Gawali
Section 12ASection 154Section 200ASection 234E

…of the matter, Revenue authorities are empowered to impose such late fee u/s.234E only for the default committed after 01.06.2015 and not prior to that. The Hon’ble Kerala High Court in Olari Little Flower Kuries Pvt. Ltd. Vs. Union of India and others (2022) 440 ITR 26 (Kerala) has affirmed the non-imposition of fee for the period prior to 01.06.2015. Similar view has been taken in Jiji Varghese VS. ITO(TDS) & Ors. (2022) 443 ITR 267 (Ker) holding that no fee u/s.234E can be imposed for the periods of the respective A.Ys. prior to 1st June, 2015. Similar view was also taken by this Tribunal in the case of Dadasa…

NEW HIGH SCHOOL,AURANGABAD vs. ACIT CENTRALIZED PROCESSING CELL -TDS, AURANGABAD

In the result, the appeal filed by the assessee in ITA

ITA 2640/PUN/2025[2014-15]Status: DisposedITAT Pune26 Mar 2026AY 2014-15

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.2638, 2640 & 2641/Pun/2025 िनधा"रण वष" / Assessment Year : 2014-15 New High School, Vs. Acit, Cpc-Tds, Tq. Jafrabad, At Post Warud, Ghaziabad. Jalna- 431206. Pan : Aabtm0727H Appellant Respondent Assessee By Shri Ashutosh Dhoot (Virtual) : Revenue By : Shri Rajesh Gawali Date Of Hearing : 09.03.2026 Date Of Pronouncement : 26.03.2026 आदेश / Order Per Vinay Bhamore, Jm: These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 10.09.2025 Passed By Ld. Addl./Jcit(A)-1, Coimbatore [‘Ld. Cit(A)’] For The Assessment Year 2014-15 Respectively. 2. Since Identical Facts & Common Issues Are Involved In All The Above Captioned Three Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 3. First, We Shall Take Up The Appeal Of The Assessee In Ita No.2638/Pun/2025 For Adjudication As The Lead Case.

For Respondent: Shri Rajesh Gawali
Section 12ASection 154Section 200ASection 234E

…of the matter, Revenue authorities are empowered to impose such late fee u/s.234E only for the default committed after 01.06.2015 and not prior to that. The Hon’ble Kerala High Court in Olari Little Flower Kuries Pvt. Ltd. Vs. Union of India and others (2022) 440 ITR 26 (Kerala) has affirmed the non-imposition of fee for the period prior to 01.06.2015. Similar view has been taken in Jiji Varghese VS. ITO(TDS) & Ors. (2022) 443 ITR 267 (Ker) holding that no fee u/s.234E can be imposed for the periods of the respective A.Ys. prior to 1st June, 2015. Similar view was also taken by this Tribunal in the case of Dadasa…

NEW HIGH SCHOOL,AURANGABAD vs. ACIT CENTRALIZED PROCESSING CELL -TDS, AURANGABAD

In the result, the appeal filed by the assessee in ITA

ITA 2638/PUN/2025[2014-15]Status: DisposedITAT Pune26 Mar 2026AY 2014-15

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.2638, 2640 & 2641/Pun/2025 िनधा"रण वष" / Assessment Year : 2014-15 New High School, Vs. Acit, Cpc-Tds, Tq. Jafrabad, At Post Warud, Ghaziabad. Jalna- 431206. Pan : Aabtm0727H Appellant Respondent Assessee By Shri Ashutosh Dhoot (Virtual) : Revenue By : Shri Rajesh Gawali Date Of Hearing : 09.03.2026 Date Of Pronouncement : 26.03.2026 आदेश / Order Per Vinay Bhamore, Jm: These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 10.09.2025 Passed By Ld. Addl./Jcit(A)-1, Coimbatore [‘Ld. Cit(A)’] For The Assessment Year 2014-15 Respectively. 2. Since Identical Facts & Common Issues Are Involved In All The Above Captioned Three Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 3. First, We Shall Take Up The Appeal Of The Assessee In Ita No.2638/Pun/2025 For Adjudication As The Lead Case.

For Respondent: Shri Rajesh Gawali
Section 12ASection 154Section 200ASection 234E

…of the matter, Revenue authorities are empowered to impose such late fee u/s.234E only for the default committed after 01.06.2015 and not prior to that. The Hon’ble Kerala High Court in Olari Little Flower Kuries Pvt. Ltd. Vs. Union of India and others (2022) 440 ITR 26 (Kerala) has affirmed the non-imposition of fee for the period prior to 01.06.2015. Similar view has been taken in Jiji Varghese VS. ITO(TDS) & Ors. (2022) 443 ITR 267 (Ker) holding that no fee u/s.234E can be imposed for the periods of the respective A.Ys. prior to 1st June, 2015. Similar view was also taken by this Tribunal in the case of Dadasa…

HUTATMA JAIWANTRAO PATIL GIRLS HIGH SCHOOL & JUNIOR COLLEGE HIMAYATNAGAR,HIMAYAT NAGAR vs. CIT TDS NASHIK, NASHIK

In the result, the appeal filed by the assessee in ITA

ITA 2449/PUN/2025[2014-15 24Q Q4]Status: DisposedITAT Pune16 Feb 2026

Bench: Shri R. K. Panda & Shri Vinay Bhamoresl.

For Appellant: Shri Y. S. Nagla
Section 200ASection 200A(1)Section 234ESection 234E(2)Section 246Section 246(1)Section 246A(1)

…of the matter, Revenue authorities are empowered to impose such late fee u/s.234E only for the default committed after 01.06.2015 and not prior to that. The Hon’ble Kerala High Court in Olari Little Flower Kuries Pvt. Ltd. Vs. Union of India and others (2022) 440 ITR 26 (Kerala) has affirmed the non-imposition of fee for the period prior to 01.06.2015. Similar view has been taken in Jiji Varghese VS. ITO(TDS) & Ors. (2022) 443 ITA Nos.2446 to 2448/PUN/2025 ITR 267 (Ker) holding that no fee u/s.234E can be imposed for the periods of the respective A.Ys. prior to 1st June, 2015. Similar view was also taken by this…

HUTATMA JAIWANTRAO PATIL GIRLS HIGH SCHOOL & JUNIOR COLLEGE HIMAYATNAGAR,HIMAYAT NAGAR vs. CIT TDS NASHIK, NASHIK

In the result, the appeal filed by the assessee in ITA

ITA 2448/PUN/2025[2014-15 24Q Q3 ]Status: DisposedITAT Pune16 Feb 2026

Bench: Shri R. K. Panda & Shri Vinay Bhamoresl.

For Appellant: Shri Y. S. Nagla
Section 200ASection 200A(1)Section 234ESection 234E(2)Section 246Section 246(1)Section 246A(1)

…of the matter, Revenue authorities are empowered to impose such late fee u/s.234E only for the default committed after 01.06.2015 and not prior to that. The Hon’ble Kerala High Court in Olari Little Flower Kuries Pvt. Ltd. Vs. Union of India and others (2022) 440 ITR 26 (Kerala) has affirmed the non-imposition of fee for the period prior to 01.06.2015. Similar view has been taken in Jiji Varghese VS. ITO(TDS) & Ors. (2022) 443 ITA Nos.2446 to 2448/PUN/2025 ITR 267 (Ker) holding that no fee u/s.234E can be imposed for the periods of the respective A.Ys. prior to 1st June, 2015. Similar view was also taken by this…

HUTATMA JAIWANTRAO PATIL GIRLS HIGH SCHOOL & JUNIOR COLLEGE HIMAYATNAGAR,HIMAYAT NAGAR vs. CIT TDS NASHIK, NASHIK

In the result, the appeal filed by the assessee in ITA

ITA 2447/PUN/2025[2014-15 24Q Q2]Status: DisposedITAT Pune16 Feb 2026

Bench: Shri R. K. Panda & Shri Vinay Bhamoresl.

For Appellant: Shri Y. S. Nagla
Section 200ASection 200A(1)Section 234ESection 234E(2)Section 246Section 246(1)Section 246A(1)

…of the matter, Revenue authorities are empowered to impose such late fee u/s.234E only for the default committed after 01.06.2015 and not prior to that. The Hon’ble Kerala High Court in Olari Little Flower Kuries Pvt. Ltd. Vs. Union of India and others (2022) 440 ITR 26 (Kerala) has affirmed the non-imposition of fee for the period prior to 01.06.2015. Similar view has been taken in Jiji Varghese VS. ITO(TDS) & Ors. (2022) 443 ITA Nos.2446 to 2448/PUN/2025 ITR 267 (Ker) holding that no fee u/s.234E can be imposed for the periods of the respective A.Ys. prior to 1st June, 2015. Similar view was also taken by this…

HUTATMA JAIWANTRAO PATIL GIRLS HIGH SCHOOL & JUNIOR COLLEGE HIMAYATNAGAR,HIMAYAT NAGAR vs. CIT TDS NASHIK, NASHIK

In the result, the appeal filed by the assessee in ITA

ITA 2446/PUN/2025[2014-15 24Q Q1]Status: DisposedITAT Pune16 Feb 2026

Bench: Shri R. K. Panda & Shri Vinay Bhamoresl.

For Appellant: Shri Y. S. Nagla
Section 200ASection 200A(1)Section 234ESection 234E(2)Section 246Section 246(1)Section 246A(1)

…of the matter, Revenue authorities are empowered to impose such late fee u/s.234E only for the default committed after 01.06.2015 and not prior to that. The Hon’ble Kerala High Court in Olari Little Flower Kuries Pvt. Ltd. Vs. Union of India and others (2022) 440 ITR 26 (Kerala) has affirmed the non-imposition of fee for the period prior to 01.06.2015. Similar view has been taken in Jiji Varghese VS. ITO(TDS) & Ors. (2022) 443 ITA Nos.2446 to 2448/PUN/2025 ITR 267 (Ker) holding that no fee u/s.234E can be imposed for the periods of the respective A.Ys. prior to 1st June, 2015. Similar view was also taken by this…

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