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“Section 200(3)”

Section References (mined)Section 200Section 200(3)818 judgments

The decision most relied on for Section 200(3) is Fatehraj Singhvi v. UOI (73 Taxmann.com 252), cited in 1,778 judgments on BharatTax.

Leading authorities on Section 200(3)

Fatehraj Singhvi v. UOI
73 Taxmann.com 252 · 2016 · High Court
1,778
citing judgments

Late fees under section 234E are not applicable for periods prior to June 1, 2015, as the amendment to section 200A inserting clause (c) was effective from that date.

Kourani v. Union OF India
83 Taxmann.com 137 · 2017 · High Court
1,708
citing judgments

The fee under Section 234E for late filing of TDS/TCS statements cannot be levied retrospectively by processing an intimation under Section 200A for defaults occurring before the amendment allowing such processing.

Fateh Raj Singhvi & Ors. v. UOI
289 CTR 602 · 2016 · High Court
844
citing judgments

A fee under Section 234E cannot be levied or adjusted in an intimation under Section 200A for TDS statements pertaining to periods prior to June 1, 2015, as the enabling amendment to Section 200A(1)(c) came into effect only from that date.

Rashmikant Kundalia v. Union of India
54 Taxmann.com 200 · 2015 · High Court
702
citing judgments

Section 234E, levying late fees for delayed filing of TDS statements under section 200(3), is constitutionally valid and constitutes a compensatory fee, not a punitive penalty. Before treating any person as an assessee-in-default, an opportunity of being heard must be provided.

Dundlod Shikshan Sansthan v. Union of India
63 Taxmann.com 243 · 2015 · High Court
397
citing judgments

The imposition of fees for late filing of TDS/TCS returns prior to the Finance Act, 2015 amendments was not illegal, and the Rajasthan High Court found no justification to interfere with such compensatory fees.

CIT v. Amitabh Bachchan
384 ITR 200 · 2016 · Supreme Court
264
citing judgments

The Commissioner's revisional power under Section 263 of the Income Tax Act is not limited to the points specified in the show-cause notice, nor is the exercise of this power contingent upon issuing a show-cause notice.

137 (Guj.) IV. Qatalys Software Technologies (P.) Ltd. v. UOI
115 Taxmann.com 345 · 2020 · High Court
178
citing judgments

The Madras High Court has upheld the validity of the levy of fees under Section 234E and penalties under Section 271H, finding the charging provision to be Section 234E, with the power to levy existing from 01/07/2012.

Krishak Bharati Cooperative Ld v. DCIT
23 Taxmann.com 265 · 2012 · High Court
147
citing judgments

The rule of consistency does not override the correct application of law and should not be applied if it leads to an anomalous outcome.

Judgments citing Section 200(3)

Rao Khem Chand Vidya Vihar Shiksha Samiti, Rewari vs. ITO-TDS, Rohtak

In the result, the appeal of the Assessee in ITA No

ITA 3856/DEL/2024[2016-17]Status: DisposedITAT Delhi06 Feb 2026AY 2016-17

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri M.R. Sahu, CAFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 12ASection 191Section 200(3)Section 200A(1)Section 201Section 234ESection 40a

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘A’ BENCH, NEW DELHI BEFORE MS. MADHUMITA ROY, JUDICIAL MEMBER, AND SHRI NAVEEN

Vivimed Labs Limited, Hyderabad vs. DCIT., Central Circle 3(4), Hyderabad

ITA 1237/HYD/2025[2022-23]Status: DisposedITAT Hyderabad21 Jan 2026AY 2022-23
For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: Shri K. Vinoth Kannan
Section 154Section 200Section 201Section 201(1)Section 220(2)Section 234ESection 250Section 311

section 220(2) of the Act for the reason that there was a delay in delivering/filing the statements within the time prescribed under section 200(3) of the Act. The assessee company has assailed the charging of the interest/fee primarily for two-fold reasons, viz., (i) that as its accountant ... relevant period taken unwell, therefore, the assessee company was prevented by sufficient cause in filing the statements in accordance with the provisions of section 200(3) of the Act; and (ii) that due to lockdown protocols the business of the assessee company was affected due to COVID- 19 during

Vivimed Labs Limited, Hyderabad vs. DCIT., Central Circle-3(4), Hyderabad

Accordingly, the appeal filed by the assessee company, being devoid and bereft of any substance, is dismissed

ITA 1236/HYD/2025[2021-22]Status: DisposedITAT Hyderabad21 Jan 2026AY 2021-22

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1236 & 1237/Hyd/2025 ("नधा"रण वष"/Assessment Year:2021-22 & 2022-23) Vivimed Labs Limited, Vs. Dcit, Hyderabad. Central Circle-3(4), Pan: Aaacv6060A Hyderabad. (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "वारा/Revenue By: Shri K. Vinoth Kannan, Sr. Ar सुनवाई क" तार"ख/Date Of 05/01/2026 Hearing: घोषणा क" तार"ख/Date Of 21/01/2026 Pronouncement: आदेश / Order

For Appellant: Shri P. Murali Mohan Rao, CAFor Respondent: Shri K. Vinoth Kannan
Section 154Section 200Section 200(3)Section 201Section 201(1)Section 220(2)Section 234ESection 250Section 311

section 220(2) of the Act for the reason that there was a delay in delivering/filing the statements within the time prescribed under section 200(3) of the Act. The assessee company has assailed the charging of the interest/fee primarily for two-fold reasons, viz., (i) that as its accountant ... relevant period taken unwell, therefore, the assessee company was prevented by sufficient cause in filing the statements in accordance with the provisions of section 200(3) of the Act; and (ii) that due to lockdown protocols the business of the assessee company was affected due to COVID- 19 during

Yashwantrao Chavan Institute of Polytechnic, Beed vs. ACIT Centralized Processing Cell - TDS, Ghaziabad

In the result, ITA.No.2049/PUN

ITA 2639/PUN/2025[2013-14]Status: DisposedITAT Pune06 Jan 2026AY 2013-14

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2637/Pun/2025 Assessment Year : 2013-14

For Appellant: Shri Shubham N. RathiFor Respondent: Shri Sanjay Dhivare
Section 154Section 200ASection 234E

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCHES “B”, PUNE BEFORE DR.MANISH BORAD, ACCOUNTANT MEMBER AND SHRI VINAY BHAMORE, JUDICIAL

Shri Shivaji College, Pune vs. ACIT, Centralized Processing Cell - TDS, Ghaziabad

In the result, ITA.No.2049/PUN

ITA 2637/PUN/2025[2013-14]Status: DisposedITAT Pune06 Jan 2026AY 2013-14

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2637/Pun/2025 Assessment Year : 2013-14

For Appellant: Shri Shubham N. RathiFor Respondent: Shri Sanjay Dhivare
Section 154Section 200ASection 234E

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCHES “B”, PUNE BEFORE DR.MANISH BORAD, ACCOUNTANT MEMBER AND SHRI VINAY BHAMORE, JUDICIAL

Bmg Calcuttawala Jewellers Pvt. Ltd., Indore vs. AO CPC (TDS), ITO TDS(1) Indore, Indore

Appeals are allowed”

ITA 136/IND/2025[2013-14]Status: DisposedITAT Indore27 Nov 2025AY 2013-14

Bench: Shri B.M. Biyani

Section 200Section 200(3)Section 200ASection 200A(1)Section 220(2)Section 234ESection 246ASection 250Section 253

late fee levied by AO in the intimation u/s 200A. However, the AO has now passed order under different provisions of law, viz. section 200(3) r.w.s. 234E creating demand of late fee. The assessee’s contention, however, remains that prior to 01.06.2015, the department had no authority to create ... demand of late fee, not even in section 200(3) r.w.s. 234E. The CIT(A) has rejected this claim of assessee by relying upon a decision of Hon’ble Gujrat High Court in Rajesh Kourani v. UOI [2017] 83 taxmann.com 137/249 Taxman 402 (Guj.) wherein it has been held that

Garrison Engineer (E/M), Maharajpur vs. ITO., (TDS), Gwalior

In the result, ITA Nos. 128 to 131/Agr/2021 and ITA Nos

ITA 135/AGR/2021[2013-14]Status: DisposedITAT Agra30 Oct 2025AY 2013-14

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 154Section 200(3)Section 250Section 272ASection 272A(2)(k)Section 274

272A(2) (k) for not filing the statement in prescribed Form No. 24Q for first Quarter as provided in section 200(3) of the Income Tax Act, 1961, whereas, the appellant being Government office was not required to file the statement in prescribed Form 24Q as provided in section 200 ... merely a technical default of not filing the statement in prescribed Form No. 24Q for first Quarter as provided in section 200(3) of the Income Tax Act, 1961, whereas the appellant had deposited /remitted the amount of TDS to the credit of the Central Government. 4.That, the appellant craves

Garrison Engineer(E/M), Maharajpur vs. ITO., (TDS), Gwalior

In the result, ITA Nos. 128 to 131/Agr/2021 and ITA Nos

ITA 134/AGR/2021[2013-14]Status: DisposedITAT Agra30 Oct 2025AY 2013-14

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 154Section 200(3)Section 250Section 272ASection 272A(2)(k)Section 274

272A(2) (k) for not filing the statement in prescribed Form No. 24Q for first Quarter as provided in section 200(3) of the Income Tax Act, 1961, whereas, the appellant being Government office was not required to file the statement in prescribed Form 24Q as provided in section 200 ... merely a technical default of not filing the statement in prescribed Form No. 24Q for first Quarter as provided in section 200(3) of the Income Tax Act, 1961, whereas the appellant had deposited /remitted the amount of TDS to the credit of the Central Government. 4.That, the appellant craves

Garrison Engineer (E/M), Gwalior vs. ITO, (TDS), Gwalior

In the result, ITA Nos. 128 to 131/Agr/2021 and ITA Nos

ITA 133/AGR/2021[2013-14]Status: DisposedITAT Agra30 Oct 2025AY 2013-14

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 154Section 200(3)Section 250Section 272ASection 272A(2)(k)Section 274

272A(2) (k) for not filing the statement in prescribed Form No. 24Q for first Quarter as provided in section 200(3) of the Income Tax Act, 1961, whereas, the appellant being Government office was not required to file the statement in prescribed Form 24Q as provided in section 200 ... merely a technical default of not filing the statement in prescribed Form No. 24Q for first Quarter as provided in section 200(3) of the Income Tax Act, 1961, whereas the appellant had deposited /remitted the amount of TDS to the credit of the Central Government. 4.That, the appellant craves

Garrison Engineer (E/M), Gwalior vs. ITO.(TDS), Gwalior

In the result, ITA Nos. 128 to 131/Agr/2021 and ITA Nos

ITA 132/AGR/2021[2013-14]Status: DisposedITAT Agra30 Oct 2025AY 2013-14

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 154Section 200(3)Section 250Section 272ASection 272A(2)(k)Section 274

272A(2) (k) for not filing the statement in prescribed Form No. 24Q for first Quarter as provided in section 200(3) of the Income Tax Act, 1961, whereas, the appellant being Government office was not required to file the statement in prescribed Form 24Q as provided in section 200 ... merely a technical default of not filing the statement in prescribed Form No. 24Q for first Quarter as provided in section 200(3) of the Income Tax Act, 1961, whereas the appellant had deposited /remitted the amount of TDS to the credit of the Central Government. 4.That, the appellant craves

Garrison Engineer (E/M), Maharajpur vs. JCIT., (TDS), Bhopal

In the result, ITA Nos. 128 to 131/Agr/2021 and ITA Nos

ITA 131/AGR/2021[2012-13]Status: DisposedITAT Agra30 Oct 2025AY 2012-13

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 154Section 200(3)Section 250Section 272ASection 272A(2)(k)Section 274

272A(2) (k) for not filing the statement in prescribed Form No. 24Q for first Quarter as provided in section 200(3) of the Income Tax Act, 1961, whereas, the appellant being Government office was not required to file the statement in prescribed Form 24Q as provided in section 200 ... merely a technical default of not filing the statement in prescribed Form No. 24Q for first Quarter as provided in section 200(3) of the Income Tax Act, 1961, whereas the appellant had deposited /remitted the amount of TDS to the credit of the Central Government. 4.That, the appellant craves

Garrison Engineer (E/M) Air Force Station, Maharjpur vs. JCIT(TDS), Bhopal

In the result, ITA Nos. 128 to 131/Agr/2021 and ITA Nos

ITA 130/AGR/2021[2012-13]Status: DisposedITAT Agra30 Oct 2025AY 2012-13

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 154Section 200(3)Section 250Section 272ASection 272A(2)(k)Section 274

272A(2) (k) for not filing the statement in prescribed Form No. 24Q for first Quarter as provided in section 200(3) of the Income Tax Act, 1961, whereas, the appellant being Government office was not required to file the statement in prescribed Form 24Q as provided in section 200 ... merely a technical default of not filing the statement in prescribed Form No. 24Q for first Quarter as provided in section 200(3) of the Income Tax Act, 1961, whereas the appellant had deposited /remitted the amount of TDS to the credit of the Central Government. 4.That, the appellant craves

Garrison Emgomeer (E/M), Air Firce Station, Maharajpur vs. JCIT.(TDS), Bhopal

In the result, ITA Nos. 128 to 131/Agr/2021 and ITA Nos

ITA 129/AGR/2021[2012-13]Status: DisposedITAT Agra30 Oct 2025AY 2012-13

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 154Section 200(3)Section 250Section 272ASection 272A(2)(k)Section 274

272A(2) (k) for not filing the statement in prescribed Form No. 24Q for first Quarter as provided in section 200(3) of the Income Tax Act, 1961, whereas, the appellant being Government office was not required to file the statement in prescribed Form 24Q as provided in section 200 ... merely a technical default of not filing the statement in prescribed Form No. 24Q for first Quarter as provided in section 200(3) of the Income Tax Act, 1961, whereas the appellant had deposited /remitted the amount of TDS to the credit of the Central Government. 4.That, the appellant craves

Garrison Emgomeer (E/M) Air Force Station, Maharajpur vs. Joint Commissioner of Income Tax, (TDS), Bhopal

In the result, ITA Nos. 128 to 131/Agr/2021 and ITA Nos

ITA 128/AGR/2021[2012-13]Status: DisposedITAT Agra30 Oct 2025AY 2012-13

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 154Section 200(3)Section 250Section 272ASection 272A(2)(k)Section 274

272A(2) (k) for not filing the statement in prescribed Form No. 24Q for first Quarter as provided in section 200(3) of the Income Tax Act, 1961, whereas, the appellant being Government office was not required to file the statement in prescribed Form 24Q as provided in section 200 ... merely a technical default of not filing the statement in prescribed Form No. 24Q for first Quarter as provided in section 200(3) of the Income Tax Act, 1961, whereas the appellant had deposited /remitted the amount of TDS to the credit of the Central Government. 4.That, the appellant craves

Padma Parakh, Rajnandgaon vs. Income Tax Officer, TDS, Bhilai

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

ITA 562/RPR/2025[2014-15]Status: DisposedITAT Raipur15 Oct 2025AY 2014-15

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.560, 561 & 562/Rpr/2025 "नधा"रण वष" / Assessment Year : 2014-15 Padma Parakh Parakh Nursing Home, Lal Bagh, Rajnandgaon-491 441 (C.G.) Pan: Ajqpp8601H

For Appellant: None (written submission)For Respondent: Dr. Priyanka Patel, Sr. DR
Section 200(3)Section 200ASection 234ESection 271HSection 272A

case of Fatheraj Singhvi (supra) are extracted as follows :- “19. Hence, it can be said that, the mechanism provided for enforceability of Section 200(3) or 206C (3) for filing of the statement by making it penal under Section 272A (2) (k) is done away in view of the insertion

Padma Parakh, Rajnandgaon vs. Income Tax Officer, TDS, Bhilai

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

ITA 561/RPR/2025[2014-15]Status: DisposedITAT Raipur15 Oct 2025AY 2014-15

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.560, 561 & 562/Rpr/2025 "नधा"रण वष" / Assessment Year : 2014-15 Padma Parakh Parakh Nursing Home, Lal Bagh, Rajnandgaon-491 441 (C.G.) Pan: Ajqpp8601H

For Appellant: None (written submission)For Respondent: Dr. Priyanka Patel, Sr. DR
Section 200(3)Section 200ASection 234ESection 271HSection 272A

case of Fatheraj Singhvi (supra) are extracted as follows :- “19. Hence, it can be said that, the mechanism provided for enforceability of Section 200(3) or 206C (3) for filing of the statement by making it penal under Section 272A (2) (k) is done away in view of the insertion

Padma Parakh, Rajnandgaon vs. Income Tax Officer, TDS, Bhilai

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

ITA 560/RPR/2025[2014-15]Status: DisposedITAT Raipur15 Oct 2025AY 2014-15

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.560, 561 & 562/Rpr/2025 "नधा"रण वष" / Assessment Year : 2014-15 Padma Parakh Parakh Nursing Home, Lal Bagh, Rajnandgaon-491 441 (C.G.) Pan: Ajqpp8601H

For Appellant: None (written submission)For Respondent: Dr. Priyanka Patel, Sr. DR
Section 200(3)Section 200ASection 234ESection 271HSection 272A

case of Fatheraj Singhvi (supra) are extracted as follows :- “19. Hence, it can be said that, the mechanism provided for enforceability of Section 200(3) or 206C (3) for filing of the statement by making it penal under Section 272A (2) (k) is done away in view of the insertion

Supreme Transport Company, Indore vs. ITO TDS-II, Indore

In the result, all the appeals filed by the assessees are allowed

ITA 917/IND/2024[2013-14]Status: DisposedITAT Indore13 Oct 2025AY 2013-14

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

Section 200(3)Section 200ASection 234E

late fee levied by AO in the intimation u/s 200A. However, the AO has now passed order under different provisions of law, viz. section 200(3) r.w.s. 234E creating demand of late fee. The assessee’s contention, however, remains that prior to 01.06.2015, the department had no authority to create ... demand of late fee, not even in section 200(3) r.w.s. 234E. The CIT(A) has rejected this claim of assessee by relying upon a decision of Hon’ble Gujrat High Court in Rajesh Kourani v. UOI [2017] 83 taxmann.com 137/249 Taxman 402 (Guj.) wherein it has been held that

Supreme Transport Company, Indore vs. ITO TDS-II, Indore

Appeal is dismissed in limine as time-barred

ITA 915/IND/2024[2013-14]Status: DisposedITAT Indore13 Oct 2025AY 2013-14

Bench: Shri B.M. Biyani & Shri Paresh M. Joshiassessment Year: 2013-14 [Financial Year: 2012-13 / Q2-26Q) M/S. Supreme Transport Ito Tds-Ii, Company, Indore 201, Vikram Tower, बनाम/ Sneh Nagar, Vs. Indore (Assessee/Appellant) (Revenue/Respondent) Pan: Aaufs5010N Assessee By Shri Subhash Chand Jain, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 08.10.2025 Date Of Pronouncement 13.10.2025

Section 200(3)Section 200ASection 234E

आयकरअपीलीयअिधकरण, इंदौर"ायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI B.M. BIYANI, ACCOUNTANT MEMBER AND

Supreme Transport Company, Indore vs. ITO TDS-II, Indore

In the result, all the appeals filed by the assessees are allowed

ITA 914/IND/2024[2013-14]Status: DisposedITAT Indore13 Oct 2025AY 2013-14

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

Section 200(3)Section 200ASection 234E

late fee levied by AO in the intimation u/s 200A. However, the AO has now passed order under different provisions of law, viz. section 200(3) r.w.s. 234E creating demand of late fee. The assessee’s contention, however, remains that prior to 01.06.2015, the department had no authority to create ... demand of late fee, not even in section 200(3) r.w.s. 234E. The CIT(A) has rejected this claim of assessee by relying upon a decision of Hon’ble Gujrat High Court in Rajesh Kourani v. UOI [2017] 83 taxmann.com 137/249 Taxman 402 (Guj.) wherein it has been held that