Sri Rujula International Vs Principal Chief Commissioner of Income Tax (Madras High Court)
Summary: The Madras High Court considered W.P.No.4307 of 2024 filed by Sri Rujula International challenging six Demand Intimation Letters dated 28.03.2019 issued by the Deputy Commissioner of Income Tax, Centralized Processing Cell–TDS. The petitioner sought a writ of certiorari to quash the impugned demand intimations relating to TDS statements.
The principal issue concerned the levy of late fee under Section 234E of the Income-tax Act, 1961 while processing TDS statements under Section 200A for assessment years 2012-13 and 2013-14. The parties submitted that the judgment in M/s. True Blue Voice India Private Ltd., and another Vs. the Chief Commissioner of Income Tax – TDS, Chennai and others, 2023 (10) TMI 1141, would squarely apply to the case.
The Court reproduced the relevant portion of the earlier judgment. That judgment considered whether, notwithstanding the introduction of Section 234E with effect from 01.07.2012, late fee could be imposed while processing TDS statements under Section 200A before the insertion of Section 200A(1)(c).
The reproduced judgment noted that Section 200A(1)(c), introduced by the Finance Bill, 2015, provided that the fee, if any, would be computed in accordance with Section 234E. The objects and reasons reproduced in the judgment stated that the existing provisions of Section 200A did not provide for determination of the fee payable under Section 234E at the time of processing TDS statements and that Section 200A was therefore proposed to be amended to enable computation of that fee while processing the TDS statement.
