No Section 234E late fees for Failure to file TDS/TCS Return prior to 01.06.2015

Garrison Engineer (E/M) Vs JCIT (TDS) (ITAT Agra) The common issue involved in these appeals is that the AO imposed late fees u/s 234E of the Act., where the enabling clause (c) was inserted in the section 200A w.e.f. 01.06.2015. Which has been confirmed by the Ld. CIT(A) relying on the of Hon’ble Gujarat High Court in the case of ‘Rajesh Kaurani vs. Union of India’, 83 com 137(Guj). In ‘Shri ‘Fatehraj Singhvi and Others’ (supra) it has been held, inter alia, as follows: “22. It is hardly required to be stated that, as per the well established principles of interpretation of stat...