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In the result, all the appeals filed by the assessees are allowed
Bench: Shri B.M. Biyani & Shri Paresh M. Joshi
TDS and furnishing the requisite statement with in due time (the said provision inserted by Finance Act 2004 w.e.f. 01/04/2005). Section 234 E which provides for levy of fees if assessee is in violation of 200(3) or 206C(3) of the Act, is inserted by F.A.2012 w.e.f. 01/07/2012 .Therefore, since both the substantive legislation (section imposing statutory liability