SRI SITA RAM RAI,DHANBAD vs. ITO TDS WARD, DHANBAD

In the result, both the appeals of the assessee stand allowed

Bench: Shri Sanjay Garg & Shri Rajesh Kumari.T.A. Nos.13&14/Ran/2022 Assessment Years: 2013-14 & 2014-15 Sri Sita Ram Rai……..….…..…………..…...…......................……...…..….. Appellant 1, New Karmik Nagar, Ism Saraidhella, Dhanbad, Jharkhand - 826004. [Pan: Afipr2324B] Vs. Ito, Tds Ward-Dhanbad………………………….……….…………….. Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Pranob Kumar Koley, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : March 01, 2023 Date Of Pronouncing The Order : April 28, 2023 Order Per Sanjay Garg: Both The Appeals Have Been Preferred By The Assessee Against The Separate Orders Dated 15.03.2022 Of The National Faceless Appeal Centre [Hereinafter Referred To As The ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). The Assessee In Both The Appeals Has Agitated The Levy Of Late Filing Fees U/S 234E Of The Act Along With Interest Thereupon Levied U/S 220(2) Of The Act. Since, Common Issues Are Involved In All The Appeals, Hence These Have Heard Together & Are Being Disposed Of By This Common Order. The Appeal In Ita No.13/Ran/2022 For Assessment Year 2013-14 Is Taken As Lead Case For The Purpose Of Narration Of Facts. 2. The Brief Facts Of The Case Are That The Assessee Deducted Tax At Source (Tds) In Respect Of Certain Payments. As Per The Provisions Of 1

234E of the Act while processing TDS return u/s 200A of the Act. It was only on 01.06.2015 that the statute was amended and clause (c) was inserted to section