Section 234E TDS Late Fee Invalid for Pre-2015 Period Due to Lack of Legal Provision

Sancheti Onions Pvt. Ltd. Vs ITO (ITAT Pune) The case involves a batch of three appeals filed by two assessees against separate orders passed by the National Faceless Appeal Centre (NFAC), Delhi under Section 250 of the Income Tax Act, 1961. The primary issue in all appeals concerns the levy of late filing fees under Section 234E of the Act for delayed submission of TDS (Tax Deducted at Source) returns for Assessment Years 2013–14, 2014–15, and 2015–16. At the outset, the Tribunal addressed a delay of 17 days in filing appeals in one of the cases. The assessee submitted an affidavit expl...