If two Constructions are Possible then one in Favour of Assessee should be Applied

Popular Catering Services Vs DCIT (ITAT Mumbai) The issue under consideration is whether late fee u/s 234E can be levied prior to 1.6.2015 i.e. prior to enactment of section 234E? ITAT states that upon careful consideration they find that learned CIT appeals has totally erred in distinguishing the decision of honourable Supreme Court in the case of vegetable products. The ratio arising from the said decision is that if two constructions are possible the one in favour of assessee should be applied. In the present case ITAT note that the decision of honourable Karnataka High Court is in favour o...