Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee
Charitable Trust v. Dy CIT [Writ Petition No. 618 of 2015, dated 12-12-2017]. However, the Ld. CIT(A) relying on the decision of the Hon'ble Gujarat High Court in Rajesh Kourani (supra) which is revenue favouring held that section 234E of the Act was a charging provision creating a charge for the levy of fees for default