Bench: Shri B.M. Biyani & Shri Paresh M. Joshi
271H, section 200 A(1)(c), Memorandum to Finance Bill 2015 and the case-laws on this issue makes following points unambiguously clear that: (a) The fee payable u/s 234E is a charging provision and the AO has no discretion at all whereas section 200A is a machinery provision enabling for processing of TDS