Section 200A(1)(c) of the Income Tax Act
Income-tax Act, 2025: s.399
Section 200A(1)(c) falls under section 200A of the Income-tax Act, 1961, which corresponds to section 399 (Processing) of the Income-tax Act, 2025.
Read section 399 of the 2025 Act
Correspondence checked against the ICAI tabular mapping of the two Acts and the BharatTax.co section commentary.
The decision most relied on for Section 200A(1)(c) is Olari Little Flower Kuries (P.) Ltd. v. UOI (440 ITR 26), cited in 614 of the 96 judgments on BharatTax that turn on this section.
Leading authorities on Section 200A(1)(c)
The fee under Section 234E of the Income-tax Act cannot be levied for defaults in filing TDS statements committed prior to June 1, 2015, as the provision for its levy became effective only from that date.
The amendment to Section 200A(1)(c) of the Income-tax Act, allowing for the levy of fees under Section 234E, is prospective in nature and applies only from June 1, 2015. Consequently, no fee under Section 234E can be levied for delayed filing of TDS/TCS statements pertaining to quarters prior to this date.
Late fees levied under section 234E are deleted if the authorities erred in sustaining the levy, especially when relying on precedents that allow for such deletion.
Late fee under section 234E and consequential interest under section 220(2) cannot be levied for Tax Deducted at Source (TDS) defaults that occurred prior to June 1, 2015.
Late fees under Section 234E of the Income-tax Act, 1961, cannot be levied for periods prior to the introduction of clause (c) to sub-section (1) of Section 200A, which enabled such imposition.
A late fee under section 234E cannot be imposed if TDS applications have been processed under section 200A. Orders levying such fees are liable to be set aside.
Orders levying late fee under Section 234E are liable to be set aside if the authorities below have erred in sustaining the levy.
The levy of fees under section 234E for delayed filing of quarterly TDS returns is confirmed as per the binding precedent of Conceria International (P.) Ltd. The court also considered that Section 200A(1)(c) was not introduced during the Assessment Years 2012-13.
Late fee levied under Section 234E of the Income Tax Act, 1961, is deleted if the authorities below erroneously sustained it without providing the assessee an opportunity to be heard regarding any delay.
Late fees under Section 234E cannot be imposed while processing TDS applications under Section 200A if Section 200A was not in effect during the relevant assessment years.