Section 234E Fee Cannot Be Levied Without Valid TDS Deduction Liability

Bhikhabhai Hirabhai Patel Vs DCIT (ITAT Ahmedabad)

The Income Tax Appellate Tribunal (ITAT) in Ahmedabad has partially allowed an appeal by Bhikhabhai Hirabhai Patel, reducing the late filing fees imposed on him for a tax-deduction-at-source (TDS) default. The judgment addresses two key legal issues: the applicability of late fees under Section 234E and the interpretation of the TDS provisions for immovable property transfers under Section 194IA.

The case arose from a TDS liability of Rs. 4,39,245 imposed on Patel for the financial year 2013

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