Section 200A,
which deals with the processing of statement of tax deducted at
source u/s 200. First of all, sub section 3 of section ... violation of section 200(3) . In
any case, the levy of fee u/s 200A in accordance with the provision
of section 234E has come
time prescribed in sub-section (3) of section 200 or the
proviso to sub-section (3) of section 206C of the Act.
4. The revenue ... section (1) of
section 200A of the Act are prospective in nature,
therefore, fee u/s 234E cannot be levied in the
statement processed
given in purported exercise of power under Section 200A are in
respect of fees under Section 234E for the period prior to 1.6.2015. As
such ... cases. It is observed on perusal of Section 200 sub
section (3) r.w.s. 206C sub-section (3) proviso that when the assessee
amount paid under section 200 or section
Page 3 of 8
ITA Nos. 387 to 390/Bang/2022
201 or section 234E and any amount ... Karnataka
High Court held that amendment made u/s. 200A
providing that fee u/s. 234E of the Act could be
computed at the time
enabling provision in
the Act u/s 200A for raising demand in respect of levy of fee u/s 234E
of the Act. The provision ... effect. Resultantly, the demand
under Section 200A for computation and intimation for the
payment of fee under Section 234E could not be made in
purported
clause (c) against any amount paid
under section 200 or section 201 or section 234E and any amount
paid otherwise ... processing statement under section 200A of the Act,
the Assessing Officer cannot make any adjustment by levying fee under
section 234E prior to 01.06.2015. Therefore
clause (c) in
section 200A has been inserted with effect from 01.06.2015 only,
the levy of fee under section 234E for any delay in filing ... issue of legality of orders passed under section 200A levying late
filing fee u/s 234E prior to 1.6.2015. The relevant para is
reproduced below
with sub-section (3) of section 200 or the proviso to
sub-section (3) of section 206C.
(4) The provisions of this section shall apply ... clause (c) against any amount paid
under section 200 or section 201 or section 234E and any amount
paid otherwise
when there was enabling provision in section 200A of the Act for
levying late fees u/s 234E of the Act, late filing fees levied ... assumption of jurisdiction by the AO
u/s 200A(1)(C) to levy fees under section 234E of the Act. Even though
the quarterly return
with sub-section (3) of
section 200 or the proviso to sub-section (3) of section 206C .
(4) The provisions of this section shall apply ... clause(c) against any amount paid under section 200 or section 201 or section
234E , and any amount paid otherwise
