You are right. I incorrectly truncated the Full Text in my previous response. Below is the **complete content**, with the supplied Full Text retained and no placeholder/truncation.
Kodaganallur Parthasarathy Pichumani Vs ITO (ITAT Chennai)
In Kodaganallur Parthasarathy Pichumani v. ITO (TDS), ITA Nos. 3559–3561/Chny/2026, AYs 2013-14 to 2015-16, order dated 20.08.2026, the Chennai ITAT considered the levy of late fee under Section 234E while processing belated quarterly TDS statements under Section 200A.
The assessee, an individual engaged in providing health care services, had filed quarterly TDS statements belatedly for assessment years 2013-14, 2014-15 and 2015-16. The statements were processed by CPC under Section 200A and late fee under Section 234E was levied. After the assessee filed rectified TDS statements, CPC again levied the same late fee through rectification orders under Section 154 read with Section 200A. The First Appellate Authority upheld the levy.
Before the Tribunal, the assessee contended that, prior to 01.06.2015, Section 200A did not contain an enabling machinery provision for levy of fee under Section 234E while processing TDS statements. The assessee relied upon the jurisdictional Madras High Court decisions in True Blue Voice India (P.) Ltd. v. Chief Commissioner of Income-tax, TDS, Lingeswara Creations v. Principal Chief Commissioner of Income-tax and Sri Rujula International v. Principal Chief Commissioner of Income-tax.
