No Late Fee Under Section 234E for TDS Returns Filed Before 01.06.2015: ITAT Pune

Dr. Khande Hospital Vs Pune ITO (ITAT Pune) In the case of Dr. Khanade Hospital vs. ITO-1, Pune (ITA No. 452/PUN/2024), the assessee challenged the levy of a late fee under Section 234E of the Income-tax Act for the delay in filing a TDS return related to the third quarter of the financial year 2012–13. The return was filed on 06.03.2013, and the core contention was that Section 234E, which imposes a fee for late filing of TDS returns, could not be applied retrospectively for periods before 01.06.2015. The CIT(A) had upheld the late fee based on the Gujarat High Court’s decision in Rajesh ...