Section 154 cannot be invoked to levying of fee u/s 234E

Dhillon And Simran Liver Vs ITO (ITAT Amritsar)

The dispute emerged when the Assessing Officer refused to address the assessee’s demand created towards the fee under Section 234E. According to the assessee, the AO (TDS-CPC) didn’t take into account the fact that the demand created was Rs. 44,840/-, significantly more than the payable amount of Rs. 8,968/-.

In an interesting turn of events, the ITAT found that the issue related to the belated filing of TDS returns and subsequent

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