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Therefore, the Revenue Authorities could not have levied late filing fees u/s 234E of the Act. The Ld. AR of the assessee also submitted that the cases of the assessee is squarely covered by the decision of the Co-ordinate Bench of the Tribunal, Nagpur (through e-Court, Pune) in the case of M/s. Rajyas Software Pvt. Ltd. Vs. ACIT, CPC-TDS, Ghaziabad & Others, in ITA No. 208/NAG/2019 and others.

5. Per contra, the Ld. DR for the Revenue submitted that in these set of appeals, the respective Ld. CIT (Appeals) had dismissed these appeals filed before them on the ground of substantial late filing fees of the appeals and without going into the merits of the cases.