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Bench: Shri B.M. Biyani & Shri Paresh M. Joshi
section to provide for the machinery provision to compute the fee payable u/s 234E at the time of processing of TDS statement and the same is enabling for processes in nature. This is very much evident on perusal of the Memorandum to the Finance Bill 2015. The same have not been considered by Hon'ble ITAT. 11