Section 206C(6) of the Income Tax Act
Income-tax Act, 2025: s.394
Section 206C(6) falls under section 206C of the Income-tax Act, 1961, which corresponds to section 394 (Collection of tax at source) of the Income-tax Act, 2025.
Read section 394 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 206C(6) is Sir Dorabji Tata Trust v. DCIT(E) (188 ITD 38), cited in 32 of the 30 judgments on BharatTax that turn on this section.
Leading authorities on Section 206C(6)
An assessment order cannot be held as erroneous and prejudicial to the revenue if the Assessing Officer conducted extensive inquiries and was satisfied with the assessee's claim during assessment proceedings.
A technical breach of filing a statutory form, such as Form 27C, can be condoned. No liability under section 206C(6A) or 206C(7) can be fastened on the assessee if the statutory form is filed, even if not furnished in time.
Late fees under section 234E can be levied for belated TDS returns filed, and processed, on or after June 1, 2015, in line with amendments to section 200A.
The levy of late fees under Section 234E of the Income-tax Act is illegal for TDS returns concerning periods prior to June 1, 2015. This is because Section 234E does not apply to assessment years before this date.
