Summary
- The Pune ITAT has declared the late fee demand under Section 234E for FY 2012-13 invalid, despite a correction statement processed in 2021.
- The Tribunal ruled that the levy was unauthorized as Section 234E could not be applied to periods before June 1, 2015, following favorable precedents from the Karnataka and Kerala High Courts.
- This decision counters previous reliance on conflicting Madras High Court rulings, emphasizing the need for jurisdictional clarity.
- The ruling reinforces a favorable legal stance for taxpayers regarding outdated TDS penalties, potentially impacting similar cases nationwide.
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