In the result, assessee’s appeals (Ms
Bench: Shri Sandeep Gosain & Shri Arun Khodpia
6. We have heard both the sides on this issue of unavailability of enabling the provisions to the Assessing Officer for levy of late filing fees on the assessee in respect of defaults of non-filing of TDS statement for the period prior to 01.06.2015. It is undisputed fact that the provisions of section 234E of the Act was originally