In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos
Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent
234 E and on considering both the above views, it appears that the opinion expressed by the Gujarat High Court in Rajesh Kourani v. UOI [2017] 297 CTR 502 that section 234E by itself creates a liability and the liability to pay the late fee is not dependent on section 200A(1)(c) which only prescribes the recovery mechanism reflects