In the result, all the appeals filed by the assessee are allowed
Bench: Shri A.D. Jain & Shri T. S. Kapoor
3) that too by expressly put bar for penalty under Section 272A by insertion of proviso to Section 272A(2), it can be said that a particular set up for imposition and the payment of fee under Section 234E was provided but, it did not provide for making of demand of such fee under Section 200A payable under Section 234E