ANJANI PRS BLENDS PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE-1(1), HYDERABAD

In the result, both the appeals are allowed

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Chary

TDS statements beyond the due date, such a levy of late fee and the interest is consequential and mandatory. 5. Its canvassed before us by the learned AR that where the legislature has inserted clause (c) to section 200A(1

ANJANI PRS BLENDS PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE-1(1), HYDERABAD

In the result, both the appeals are allowed

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Chary

TDS statements beyond the due date, such a levy of late fee and the interest is consequential and mandatory. 5. Its canvassed before us by the learned AR that where the legislature has inserted clause (c) to section 200A(1

VIVIMED LABS LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE 3(4), HYDERABAD

TDS),\nCPC, Ghaziabad, considering the TDS/TCS statements passed orders under\nsection(s) 200A/206CB r.w.s 154 r.w.s 200A for the respective quarters,\nwherein demands under section 201(1A), 234E and 220(2) were raised, as\nunder:\nForm No.\nQuarter\nDate of Date of\nfiling of\nfiling of\nquarterly rectification\nreturn\nOrder u/s.\nby CPC\nDate of 234E

SOWBHAGYA BIOTECH PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD (TDS)-2(2), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

c) to (f) of sub-section (1) of Section 200A can be read as having prospective effect and not having retroactive character or effect. Resultantly, the demand under Section 200A for computation and intimation for the payment of fee under Section 234E could not be made in purported exercise of power under Section 200A by the respondent for the period

SOWBHAGYA BIOTECH PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD (TDS)-2(2), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

c) to (f) of sub-section (1) of Section 200A can be read as having prospective effect and not having retroactive character or effect. Resultantly, the demand under Section 200A for computation and intimation for the payment of fee under Section 234E could not be made in purported exercise of power under Section 200A by the respondent for the period

SOWBHAGYA BIOTECH PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD (TDS)-2(2), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

c) to (f) of sub-section (1) of Section 200A can be read as having prospective effect and not having retroactive character or effect. Resultantly, the demand under Section 200A for computation and intimation for the payment of fee under Section 234E could not be made in purported exercise of power under Section 200A by the respondent for the period

SOWBHAGYA BIOTECH PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD (TDS)-2(2), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

c) to (f) of sub-section (1) of Section 200A can be read as having prospective effect and not having retroactive character or effect. Resultantly, the demand under Section 200A for computation and intimation for the payment of fee under Section 234E could not be made in purported exercise of power under Section 200A by the respondent for the period

SOWBHAGYA BIOTECH PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD (TDS)-2(2), HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

c) to (f) of sub-section (1) of Section 200A can be read as having prospective effect and not having retroactive character or effect. Resultantly, the demand under Section 200A for computation and intimation for the payment of fee under Section 234E could not be made in purported exercise of power under Section 200A by the respondent for the period

SOWBHAGYA BIOTECH PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD(TDS)-2(2),, HYDERABAD

In the result, the appeal of the assessee is allowed

Bench: Shri R.K. Panda, Vice- & Shri Laliet Kumar

c) to (f) of sub-section (1) of Section 200A can be read as having prospective effect and not having retroactive character or effect. Resultantly, the demand under Section 200A for computation and intimation for the payment of fee under Section 234E could not be made in purported exercise of power under Section 200A by the respondent for the period

LADE MADWESH,KADAPA vs. INCOME TAX OFFICER, WARD-(2), KADAPA

In the result, appeal filed by the assessee is dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.546/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2017-18 Lade Madwesh Vs. Income Tax Officer Kadapa Ward-2 Pan:Aabhl5201M Kadapa (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Kumar Pal Tated, Ca राज" व "ारा/Revenue By:: Shri Rahul Singhania, Dr सुनवाई की तारीख/Date Of Hearing: 16/05/2024 घोषणा की तारीख/Pronouncement: 22/05/2024

c) amend any intimation under sub-section (1) of section 200A; (d) amend any intimation under sub-section (1) of section 206CB.” 10. From perusal of above it is absolutely clear that any mistake which is apparent from record can only be rectified u/s 154 of the Act. Further Hon'ble Supreme Court in the case of T. S. Balaram

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

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

C” Bench, Kolkata in the case of Madhu Bhardwaj vs. ITO, Ward-43(1), Kolkata in ITA No.30/Kol/2023, we find that as the same is distinguishable based on the facts therein involved, thus, the same would not advance the case of the assessee company before us. 21. Apropos the interest under section 201(1A) of the Act levied upon

NIRMALA INFRA PROJECTS INDIA PRIVATE LIMITED,HYDERABAD vs. ITO, WARD TDS-2(1), HYDERABAD

In the result, appeal of assessee in ITA

Bench: Shri R.K. Panda & Shri Laliet Kumar

TDS statements for the period prior to 01.06.2015 i.e. the date from which the clause (c) of sub section (1) of section 200A

NIRMALA INFRA PROJECTS INDIA PRIVATE LIMITED,HYDERABAD vs. ITO, WARD TDS-2(1), HYDERABAD

In the result, appeal of assessee in ITA

Bench: Shri R.K. Panda & Shri Laliet Kumar

TDS statements for the period prior to 01.06.2015 i.e. the date from which the clause (c) of sub section (1) of section 200A

NIRMALA INFRA PROJECTS INDIA PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE-5(1), HYDERABAD

In the result, appeal of assessee in ITA

Bench: Shri R.K. Panda & Shri Laliet Kumar

TDS statements for the period prior to 01.06.2015 i.e. the date from which the clause (c) of sub section (1) of section 200A

NIRMALA INFRA PROJECTS INDIA PRIVATE LIMITED ,HYDERABAD vs. ITO, WARD TDS-2(1), HYDERABAD

In the result, appeal of assessee in ITA

Bench: Shri R.K. Panda & Shri Laliet Kumar

TDS statements for the period prior to 01.06.2015 i.e. the date from which the clause (c) of sub section (1) of section 200A

COSYN LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , TDS, CIRCLE-1(1), HYDERABAD

Bench: Shri S.S. Godara & Shri Laxmi Prasad Sahum.A.Nos.85 & 86/Hyd/2021 (Arising Out Of Ita Nos.64 & 65/Hyd/2019) Assessment Years: 2016-17 & 2017-18 M/S. Cosyn Limited, The Deputy Commissioner (Formerly Known As Of Income Tax, Css Technergy Limited). Tds, Circle 1(1), Hyderabad. Hyderabad. Pan No.Aabcc3628G. (Appellant) (Respondent) Assessee By: Sri Praveen Nair For Sri Karan Talwar. Revenue By: Sri Swapnil Patil. Date Of Hearing: 04/02/2022 Date Of Pronouncement: 16/02/2022 Order Per S. S. Godara, J.M. These Revenue’S Twin Miscellaneous Applications Filed U/S 254(2) Of The Income Tax Act, 1961 (In Short ‘Act’) Seek To Recall Our Impugned Common Order 11.06.2021 Deleting Section 200A R.W.S. 234E Late Filing Fee; Involving Varying Sums, Respectively. Heard Both The Parties. Case Files Perused.

TDS, Circle 1(1), Hyderabad. Hyderabad. PAN No.AABCC3628G. (Appellant) (Respondent) Assessee by: Sri Praveen Nair for Sri Karan Talwar. Revenue by: Sri Swapnil Patil. Date of hearing: 04/02/2022 Date of pronouncement: 16/02/2022 ORDER Per S. S. Godara, J.M. These Revenue’s twin miscellaneous applications filed u/s 254(2) of the Income Tax Act, 1961 (in short ‘Act’) seek to recall

COSYN LIMITED,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , TDS, CIRCLE-1(1), HYDERABAD

Bench: Shri S.S. Godara & Shri Laxmi Prasad Sahum.A.Nos.85 & 86/Hyd/2021 (Arising Out Of Ita Nos.64 & 65/Hyd/2019) Assessment Years: 2016-17 & 2017-18 M/S. Cosyn Limited, The Deputy Commissioner (Formerly Known As Of Income Tax, Css Technergy Limited). Tds, Circle 1(1), Hyderabad. Hyderabad. Pan No.Aabcc3628G. (Appellant) (Respondent) Assessee By: Sri Praveen Nair For Sri Karan Talwar. Revenue By: Sri Swapnil Patil. Date Of Hearing: 04/02/2022 Date Of Pronouncement: 16/02/2022 Order Per S. S. Godara, J.M. These Revenue’S Twin Miscellaneous Applications Filed U/S 254(2) Of The Income Tax Act, 1961 (In Short ‘Act’) Seek To Recall Our Impugned Common Order 11.06.2021 Deleting Section 200A R.W.S. 234E Late Filing Fee; Involving Varying Sums, Respectively. Heard Both The Parties. Case Files Perused.

TDS, Circle 1(1), Hyderabad. Hyderabad. PAN No.AABCC3628G. (Appellant) (Respondent) Assessee by: Sri Praveen Nair for Sri Karan Talwar. Revenue by: Sri Swapnil Patil. Date of hearing: 04/02/2022 Date of pronouncement: 16/02/2022 ORDER Per S. S. Godara, J.M. These Revenue’s twin miscellaneous applications filed u/s 254(2) of the Income Tax Act, 1961 (in short ‘Act’) seek to recall

KATEPALLY VENKATA SUBRAMANYAM ,KURNOOL vs. INCOME TAX OFFICER (TDS),WARD-1, KURNOOL

In the result, these three appeals of the assessee are allowed

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

1) Clauses(c), (d) and (f) of the Act are effective from 1.6.2015 and therefore the intimation under Section 200A of the Act in respect of prior period to 1.6.2015 is without any authority under law and is not sustainable. Whereas the intimation under Section 200A of the Act for the Asst. Year 2014-15 was passed